PROCEEDINGS
WATER QUALITY CRITERIA
AND STANDARDS FOR THE
21ST CENTURY
4TH NATIONAL CONFERENCE
September 13-15, 1994
Arlington, VA
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Conference Proceedings were prepared by Gerri Wyer, Wyer Management Associates under
Purchase Order No. 4W-2750-TASA for the U.S. Environmental Protection Agency. The
contents do not necessarily reflect the views and policies of the U.S. Environmental Protection
Agency, nor does mention of trade names or commercial products constitute endorsement or
recommendation for use.
Conference was managed by Ogden Environmental and Energy Services Company, Inc. and
Science applications International Corporation under contract No. 68-C1-0033 for the U.S.
Environmental Protection Agency. The contents do not necessary reflect the views and
policies of the U.S. Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
ACKNOWLEDGMENT
These proceedings are based primarily on U.S. Environmental Protection Agency files.
The EPA thanks everyone who contributed to this publication for their time and effort. Special
thanks go to William Kramer for his diligence and excellent coordination skills to this project.
Thanks, too, go to the staff of the Science Applications International Corporation
(SAIC), the Ogden Environmental and Energy Services Company, Inc. and to Gerri Wyer, Wyer
Management Associates for their assistance in the preparation of this publication.
To obtain copies, contact:
U.S. Environmental Protection agency
Office of Water
Office of Science and Technology
Mail Code 4301
Washington, DC 20460
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PROGRAM AGENDA
WATER QUALITY CRITERIA AND STANDARDS FOR THE 21ST CENTURY
FOURTH NATIONAL CONFERENCE
ARLINGTON, VIRGINIA
SEPTEMBER 13-15, 1994
TUESDAY, SEPTEMBER 13
9:00 WELCOME PLAZA BALLROOM AND WASHINGTON
Tudor T. Davfes, Director, Office of Science and Technology (OST),
U.S. EPA
KEY NOTE :-f PLAZA BALLROOM AND WASHINGTON
Carol Browner, Administrator, U.S. EPA
CONFERENCE INTRODUCTION
Margaret Stasikowski, Director, Health and Ecological Criteria Division,
OST, U.S. EPA
10:30 Break
10:45 SESSION 1 NEW WAYS TO EVALUATE RISK: MOVING BEYOND
CHEMICAL TOXICITY IN THE WATER COLUMN
PLAZA BALLROOM AND WASHINGTON
Amy Leaberry, OST, U.S. EPA - Session Moderator
A DIFFERENT FOCUS FOR THE SCIENCE BEHIND CRITERIA
James J. Reisa, Ph.D., National Research Council
CRITERIA DEVELOPMENT PAST, PRESENT, AND FUTURE
Morris Flexner, U.S. EPA, Region 4
Edward B. Swain, Minnesota Pollution Control Agency
12:00 Break for Lunch
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TUESDAY, SEPTEMBER 13 (Continued)
1:30 CRITERIA DEVELOPMENT PAST, PRESENT, AND FUTURE
PLAZA BALLROOM AND WASHINGTON
Amy Leaberry, OST, U.S. EPA - Panel Moderator
Panel
Robert T. Angelo, Ph.D., Kansas Department of Health and Environment
Philip G. Watanaber Ph.D., Dow Chemical Company
Tim A. Eder, National Wildlife Federation
2:45 Break
3:00 SESSION 2 ADDRESSING ECOLOGICAL INTEGRITY: MOVING BEYOND
CHEMICAL TOXICITY PLAZA BALLROOM AND WASHINGTON
Susan Jackson, OST, U.S. EPA - Session Moderator
ADDRESSING NUTRIENT OVERENRICHMENT AND HABITAT
DEGRADATION
Richard Batiuk, Chesapeake Bay Program Office, U.S. EPA, Region 3
Panel
Chris O. Yoder, Ohio Environmental Protection Agency
Geoffrey W. Harvey, Idaho Department of Health and We/fare
Tom Fontaine, South Florida Water Management District
ADDRESSING HYDROLOGIC MODIFICATION AND HABITAT LOSS
Max H. Dodson, U.S. EPA, Region 8
Jerry Johns, California State Water Resources Control Board
Panel
Patrick Wright, U.S. EPA, Region 9
Estyn R. Mead, U.S. Fish and Wildlife Service
David P. Braun, The Nature Conservancy
5:45 End
6:30 - 8:30 RECEPTION FEDERAL HALL
POSTER SESSION
COMPUTER MODELING DEMONSTRATION
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WEDNESDAY, SEPTEMBER 14
8:30 OPENING COMMENTS
PLAZA BALLROOM AND WASHINGTON
Robert Perciasepe, Assistant Administrator, Office of Water, U.S. EPA
9:00 SESSION 3 ECOLOGICAL RISKS AT THE WATERSHED
LEVEL: INTEGRATING ASSESSMENTS TO SOLVE
COMPLEX PROBLEMS PLAZA BALLROOM AND WASHINGTON-
Suzanne K. M. Marcy, Ph.D.,. OST, U.S. EPA - Session Moderator
Brian D. Richter, The Nature Conservancy
William S. Whitney, Prairie Plains Resource Institute
Donna F. Sefton, Office of Wetlands, Oceans, and Watersheds, U.S. EPA
Kevin J. Beaton, Idaho Office of Attorney General
10:15 Break
10:30 BREAKOUT GROUP DISCUSSIONS:
PROTECTING ENDANGERED SPECIES
PLAZA BALLROOM
John E. Miller, Office of Solid Waste and Emergency Response
(OSWER), U.S. EPA - Panel Moderator
Panel -
Bill Kittrell, The Nature Conservancy
Jack Edmundson, U.S. Department of Agriculture
Ren Lohoefener, Ph.D., U.S. Fish and Wildlife Service
Janet McKegg, Maryland Department of Natural Resources
PROTECTION THROUGH IMPROVED LAND USE PLANNING
WASHINGTON
Susan M. Cormier, Ph.D., Office of Research and Development (ORD),
U.S. EPA - Panel Co-moderator
Marc A. Smith, Ohio Environmental Protection Agency -
Panel Co-moderator
Panel
Chris O. Yoder, Ohio Environmental Protection Agency
Steven I. Gordon, Ph.D., Ohio State University
Christine R. Furr, Christine Furr Consulting
Alan Randall, Ph.D., Ohio State University
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WEDNESDAY, SEPTEMBER 14 (Continued)
• COMPETING DEMANDS FOR WATER FEDERAL HALL
Donna F. Sefton, OWOW, U.S. EPA - Panel Moderator
Panel
Richard Anderbery, Tri-Basin Natural Resources District
Jeremiah (Jay) Maher, Central Nebraska Public Power & Irrigation
District
John Bender, Nebraska Department of Environmental Quality
William S. Whitney, Prairie Plains Resource Institute
Paul J. Currier, Ph.D., Platte River Whooping Crane Trust
• MANAGING OVER-ENRICHMENT FROM AIR, LAND, AND WATER
WILSON-HARRISON
Maggie Geist, Waquoit Bay National Estuarine Research Reserve -
Panel Co-moderator
Joseph E. Costa, Buzzards Bay Project - Panel Co-moderator
Panel
Jennie Myers, Consultant to The Nature Conservancy
Latin America - Caribbean Division
Richard Bat/uk, Chesapeake Bay Program Office, U.S. EPA, Reg/on 3
• CONFLICTING USES AND THEIR IMPACTS - HOW TO MANAGE
THEM COMMONWEALTH AUDITORIUM
Pat drone, U.S. EPA, Region 10 - Panel Moderator
Panel
Peter Bowler, University of California
Bob Muffley, Gooding County
Larry R. Wimer, Idaho Power Company
Kevin J. Beaton, Idaho Office of Attorney General
Don Brady, OWOW, U.S. EPA
12:00 Break for Lunch
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WEDNESDAY, SEPTEMBER 14 (Continued)
1:15
2:30
2:45
4:15
4:30
SESSION 4 COMPREHENSIVE STATE WATER PROGRAMS
OF THE FUTURE PLAZA BALLROOM AND WASHINGTON
Margarete Heber, OST, U.S. EPA - Session Moderator
Panel
Cynthia Dougherty, Director, Permits Division, Office of Wastewater
Management (OWM), U.S. EPA
Steve W. Tedder, North Carolina Department of Environment,
Health and Natural Resources
Michael A. Ruszczyk, Eastman Kodak Company
Jessica C. Land man, Natural Resources Defense Council
Break
SESSION 4 CONTINUED
PLAZA BALLROOM AND WASHINGTON
Break
AD HOC SESSIONS:
• TMDLs AND THE WATERSHED PROTECTION APPROACH
PLAZA BALLROOM
Russ Kinerson, OST, U.S. EPA - Co-moderator
Don Brady, OWOW, U.S. EPA - Co-moderator
Panel
Dale Bryson, U.S. EPA, Region 5
Geoffrey H. Grubbs, OWOW, U.S. EPA
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WEDNESDAY, SEPTEMBER 14 (Continued)
WILSON-HARRISON
IMPLEMENTING THE ENDANGERED SPECIES ACT
David Sabock, OST, U.S. EPA - Moderator
Panel
John Christian,. U.S. Fish and Wildlife Service
Robert F. (Mike) McGhee, U.S. EPA, Region 4
Robert J. Smith, Competitive Enterprise Institute
ASSESSING AND REPORTING TOXICS IN SEDIMENT AND FISH
WASHINGTON
Thomas M. Armitage, OSTf U.S. EPA - Moderator
Panel
Catherine A. Fox, OST, U.S. EPA
Jeffrey D. Bigler, OST, U.S. EPA
William F. (Rick) Hoffmann, OST, U.S. EPA
MONITORING TO SUPPORT THE WATERSHED PROTECTION
APPROACH COMMONWEALTH AUDITORIUM
Elizabeth Fellows, OWOW, U.S. EPA - Moderator
Panel
James G. Home, OWM, U.S. EPA
Charles A. Kanetsky, U.S. EPA, Region 3
Chris O Yoder, Ohio Environmental Protection Agency
6:00 End of Day
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THURSDAY, SEPTEMBER 15
8:30 SESSION 5 MANAGING RISK:
IMPLEMENTATION
LIMITATIONS AND BARRIERS TO
PLAZA BALLROOM AND WASHINGTON
Chris Zarba, OST, U.S. EPA - Session Moderator
Robert Paulson, Wisconsin Department of Natural Resources
Julie DalSoglio, U.S. EPA, Region 8
Ed Stigall, Chesapeake Bay Program Office, U.S. EPA, Region 3
W. William Weeks, The Nature Conservancy
10:00 Break
10:15 BREAKOUT GROUP DISCUSSIONS
Group 1 - Robert Paulson - Group moderator
Group 2 - Julie DalSoglio - Group moderator
Group 3 - Ed Stigall - Group moderator
Group 4 - W. William Weeks - Group moderator
PLAZA BALLROOM
WASHINGTON
COMMONWEALTH AUDITORIUM
WILSON-HARRISON
11:30 Break for Lunch
1:00 SUMMARY AND CONCLUSIONS
PLAZA BALLROOM AND WASHINGTON
2:15
Betsy Souther/and, Director, Standards and Applied Science Division,
OST, U.S. EPA - Moderator
Amy Leaberry, OST, U.S. EPA
Susan Jackson, OST, U.S. EPA
Suzanne Marcy, OST, U.S. EPA
Margarete Heber, OST, U.S. EPA
Chris Zorba, OST, U.S. EPA
Break
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THURSDAY, SEPTEMBER 15 (Continued)
2:30 STAKEHOLDER OBSERVATIONS
PLAZA BALLROOM AND WASHINGTON
Betsy Southerland, Director, Standards and Applied Science Division,
OST, U.S. EPA - Moderator
Darren O/sen, Nez Perce Tribe
Joel Cross, Illinois Environmental Protection Agency
Robert Berger, East Bay Municipal Utility District
Mary Buzby, Merck & Company, Inc.
Jessica Landman, National Resources Defense Council
3:30 CLOSING REMARKS
Tudor T. Davies, Director, OST, U.S. EPA
4:00 Break
4:15 AD HOC SESSIONS - TO BE ANNOUNCED
5:00 End of Conference
PLAZA BALLROOM AND WASHINGTON
ROOMS To BE ANNOUNCED*
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CONTENTS
Page
WELCOME
Welcome 0-1
Tudor Davies
Keynote Address 0_3
Carol Browner, Administrator, EPA
Conference Introduction 0-11
Margaret Stasikowski
SESSION 1 NEW WAYS TO EVALUATE RISK: MOVING BEYOND CHEMICAL
TOXICITY IN THE WATER COLUMN
New Way to Evaluate Risk: Moving Beyond Chemical Tox/c/ty in
the Water Column 1 _i
Amy L. Leaberry
A Different Focus for the Science Behind Criteria 1-5
James J. Reisa
CRITERIA DEVELOPMENT PAST, PRESENT, AND FUTURE
New Ways to Evaluate Risk: Moving Beyond Chemical Toxicity in
the Water Column 1 _g
Morris Flexner
From Sources to Fate and Effects: An Integrated Approach
to Mercury Control 1 ,-j 7
Edward B. Swain
Criteria Development Past, Present, and Future 1-19
Robert T. Angelo, Ph.D.
Criteria Development Past, Present, and Future 1-21
Philip G. Watanabe, Ph.D.
Criteria Development Past, Present, and Future 1-23
Tim A. Eder
Session 1 - Questions and Answers 1.25
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SESSION 2 ADDRESSING ECOLOGICAL INTEGRITY:
MOVING BEYOND CHEMICAL TOXICITY
Addressing Ecological Integrity: Moving Beyond
Chemical Toxicity 2~1
Susan Jackson
Nutrient Enrichment, Habitat, and Resources Restoration
Goal Setting in the Chesapeake Bay Program 2-2
Richard Batiuk
Addressing Nutrient Overenrichment and
Habitat Degradation - - - 2'5
Chris O. Yoder
Water Quality Criteria for Uncontaminated
Sediments - 2~7
Geoffrey W. Harvey
Addressing Nutrient Overenrichment and
Habitat Degradation 2'9
Tom Fontaine
Questions and Answers 2"^ ^
ADDRESSING HYDROLOGIC MODIFICATION AND
HABITAT LOSS
Water Quality in the Arid West: Is There a Role for
EPA in Advancing Solutions to the Conflicts Between
Instream Flow and Hydrologic Modification 2-13
Max H. Dodson
Establishing Standards for California's San Francisco
Bay/Sacramento - San Joaquin Delta Estuary 2'15
Jerry Johns
Addressing Hydrologic Modification and Habitat Loss 2-17
Patrick Wright
Tools to Assess the Impacts of Hydrologic Modification
on Aquatic Communities • 2-19
Estyn R. Mead
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Addressing Hydrologic Modification and Habitat Loss 2-25
David P. Braun
Session 2 - Questions and Answers 2-29
OPENING COMMENTS
Introduction OC-1
Tudor T. Davies
Opening Comments OC-3
Robert Perciasepe, Asst. Administrator, Office of Water
Questions and Answers OC-11
SESSION 3 ECOLOGICAL RISKS AT THE WATERSHED LEVEL:
INTEGRATING ASSESSMENTS TO SOLVE COMPLEX PROBLEMS
Ecological Risks at the Watershed Level 3-1
Suzanne K. M. Marcy, Ph.D.
Ecosystem Analysis for Biodiversity Conservation:
Some Perspectives From the Nature Conservancy „ 3-7
Brian D. Richter
Selecting What to Protect in the Watershed Ecosystem:
Using Multiple Assessment End points for the Middle
Platte River System 3-11
William Whitney & Donna Sefton
Managing Conflicting Uses in the Middle Snake River ; 3-13
Kevin J. Beaton
General Conclusions from Participant Feedback 3-14
SESSION 3 BREAKOUT GROUP PANEL DISCUSSIONS
Protecting Endangered Species
Panel Discussions
John E. Miller 3-15
Bill Kittrell .".'.'."! 3-15
Jack Edmundson 3-16
Ren Lohoefener 3-16
in
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Janet McKegg 3-19
Major Issues and Recommendations from Discussion 3-20
Questions and Answers 3-21
PROTECTION THROUGH IMPROVED LAND USE PLANNING
Susan Cormier, Ph.D & Marc A. Smith 3-25
Incorporating Ecological Concepts and Biological
Criteria in Ecological Risk and Watershed
Management 3~26
Chris O. Yoder
Challenges in Developing Environmental Indicators
to Assess the Cumulative Impact of Watershed
Development 3~29
Thomas R. Schueler
Land Use Planning at Watershed Scale to Reduce
Ecological Risk: Conflicts Between National and
Local Controls 3-29
Steven I. Gordon, Ph.D.
Salamanders in Suburbia: Meeting the Challenges
of Critical Resource Preservation While Maintaining
Private Property Rights 3-31
Christine R. Furr
A Practical Morality for Conservation at the
Watershed Level , 3-31
Alan Randall, Ph.D.
Major Issues and Recommendations from Discussion 3-33
Questions and Answers 3-34
COMPETING DEMANDS FOR WATER
Donna F. Sefton 3-35
Panel
Richard Anderberry 3-35
Jeremiah Maher 3-39
John Bender 3-39
IV
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William Whitney 3-39
Paul J. Currier, P.D 3-40
Issues and Recommendations from Discussion 3-41
Questions and Answers 3-41
MANAGING OVER-ENRICHMENT FROM AIR, LAND, AND WATER
Nutrient Enrichment of Waquoit Bay, Massachusetts 3-45
Maggie A. Geist
Nitrogen TMALs for Buzzards Bay Embayments 3-46
Joseph E. .Costa
Value of Wetland Transition Zones in Protecting
the Nutrient Balance of Coastal Watershed Ecosystems:
Talamanca-Caribbean Biological Corridor, Costa Rica 3-48
Jennie Myers
Chesapeake Bay Program 3-51
Richard Batiuk
Issues and Recommendations from Discussion 3-51
Questions and Answers 3-52
CONFLICTING USES AND THEIR IMPACTS - HOW TO MANAGE THEM
Pat Cirone 3-53
Panel
The Middle Snake River; Ecological Risk Assessment
and Strategies for Recovery 3-53
Peter A. Bowler
Bob Muffley . / 3-61
Larry R. Wimer 3-62
Managing Conflicting Uses in the Middle Snake River . . . 3-63
Kevin J. Beaton
Don Brady 3-68
Issues and Recommendations from Discussion 3-68
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Questions and Answers 3-69
SESSION 4 COMPREHENSIVE ENVIRONMENTAL PROGRAM OF THE FUTURE:
WHERE ARE WE NOW AND WHERE ARE WE GOING
Margaret Heber 4-1
Cynthia Dougherty 4-5
Steve W. Tedder 4:7
Michael A. Ruszczyk 4-9
Comprehensive Environmental Programs of the Future:
A 21st Century Vision of Effective State Watershed
Protection Programs 4-11
Jessica C. Landman
Questions and Answers 4-14
SESSION 4 AD HOC
TMDLs AND THE WATERSHED PROTECTION PROGRAM
Russ Kinnerson 4-19
Dale Bryson 4-19
Geoffrey H. Grubbs 4-21
Questions and Answers 4-23
IMPLEMENTING THE ENDANGERED SPECIES ACT
Implementing the Endangered Species Act 4-25
David Sabock
Aquatic Ecosystem Protection Through the
Endangered Species Act 4-25
John Christian
VI
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An Alternate View on the Endangered Species Act
and EPA's Water Quality Criteria Development
and Standards Approval 4-33
Robert F. (Mike) McGhee & Duncan M. Powell
Implementing the Endangered Species Act 4-35
Robert J. Smith
Questions and Answers 4-37
ASSESSING TOXICITY IN SEDIMENT AND FISH
Tools for Environmental Managers and Decision-Makers 4-39
Thomas M. Armitage
The National Sediment Inventory: A Tool for
Environmental Managers and Decision-Makers 4-41
Catherine A. Fox
National Guidance for Assessing the Risks of Consuming
Chemically Contaminated Fish , 4-43
Jeffrey D. Bigler
EPA's Fish Tissue Data Repository 4-45
William F. (Rick) Hoffman
Questions and Answers 4-46
MONITORING TO SUPPORT THE WATERSHED PROTECTION APPROACH
Elizabeth Fellows 4-49
James G. Home 4-53
Charles A. Kanetsky . 4-55
Chris O. Yoder 4-57
SESSION 5 MANAGING RISK: LIMITATION AND BARRIERS TO IMPLEMENTATION
Chris Zarba 5-1
Nature Conservancy Bioreserve . 5-1
Robert Paulson
VII
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Milltown Reservoir—Clark Fork River, Montana: A
Comprehensive Ecological Risk Assessment Project 5-3
Julie DalSoglio
Chesapeake Bay Program Experience with Nutrient Load
Allocations Managing Risk: Lessons Learned
and Overcome Barriers , 5-5
Ed Stigall
Nature Conservancy Bioreserve 5-9
W. William Weeks
Questions and Answers 5-11
SESSION 5 - BREAKOUT GROUP DISCUSSIONS
GROUP I
Robert Paulson 5-13
Questions and Answers 5-13
GROUP 2
Julie DalSoglio 5-19
Questions and Answers 5-19
GROUP 3
Ed Stigall 5-21
Questions and Answers 5-21
GROUP 4
W. William Weeks 5-25
SUMMARY AND CONCLUSIONS
Betsy Southerland 6-1
VIII
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Stakeholder Observations - Tribal Perspective
Darren Olsen 6-3
Stakeholder Observations - State Perspective
Joel Cross . . . 6-5
Stakeholder Observations - Municipality Perspective
Robert Berger 6-7
Stakeholder Observations - Industry Perspective
Mary Buzby 6-11
Stakeholder Observations - Environmental Perspective
Jessica Landman 6-15
Comments from Audience 6-19
CLOSING REMARKS
Tudor T. Davies 6-25
APPENDICES
Appendix A: Speaker List
Appendix B: Attendees List
IX
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I I
Opening Session
TT
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Water Quality Criteria and Standards for the 21st Century
WELCOME
Tudor T. Davies
Director, Office of Science and Technology -
U.S. EPA
Good Morning, We have a very tight agenda for the next couple of days. I am real pleased
to see you all here. As you know, a great deal of work goes into a conference like this, and
we had a lot of people preregistered. We had no cash on the barrel and we were not sure
how many of you would turn up. I am thrilled to see how many of you have come, and how
diverse the audience is.
We are very excited because the topic of the conversation that we will have with you over
the next three days is future directions on criteria and standards, particularly as we move
towards a watershed approach. And, we have here today a great variety of people who
represent many thoughts and many ideas. We have people here from EPA, from industry,
private companies, from States, municipalities, other federal agencies, environmental groups,
academic people here who will help us think about the academic functions. And we also have
an international audience that I would like you to get to know as you walk around the
corridors over the next couple of days. We have people here from Indonesia, Malasia, the
Phillipines, Singpore and Thailand who are attending the conference as part of a cooperative
activity with Canada. They are developing criteria and standards for the marine environment
and for human health for their nations. I hope that as they ask questions and as we have a
dialogue here, you will give them the benefits of your experience.
It's sort of difficult starting off cold on a morning like this. My staff know that I tell a joke
very poorly and so they have given up on providing me stories to tell. Dave Sabock did a
great job at the last standards conference we had almost two years ago in Las Vegas and I
totally blew his joke, so he gave up on me.
We are looking forward to the conference. We have a wide variety of speakers and we really
do want you to participate in the dialogue. We are looking forward to having some guidance
out of this conference. We are looking forward to an evolution of our program based upon
the things that you are going to tell us over the next few days.
I am really pleased, in fact delighted that our Administrator, Carol Browner could come to
welcome you this morning and give you some of her insights. Carol has been in EPA now
getting on for two years. And, we are really thrilled with the things that she has been
involved with and the strong support that she has given to the water program. She and Bob
Perciasepe have worked very hard on reauthorization issues and in looking at where our
program is evolving. She brings, as Bob does, experience from State government and from
the national program. Her perspective as a mother with a young child also influences where
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Davies
she wants to see the Environmental Protection Agency go and where the environmental
movement in this country should progress. She has been refreshing, interesting and delightful
for us. We are thrilled with her energy and her enthusiasm, which as I am sure she will
convey to you this morning.
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Browner
Water Quality Criteria and Standards for the 21st Century
KEYNOTE ADDRESS
Carol Browner
Administrator
U.S. Environmental Protection Agency
Washington, DC
Thank you Tudor, and thank all of you for the opportunity to be with you this morning. I
understand that we have had such a strong interest in this conference that there are actually
a number of individuals viewing this conference from another room and I give a special
welcome to those people who are not in here with us.
It is a pleasure to welcome you all to this very, very important conference. We hope and we
believe that this conference will assist and help us in charting a course in water quality criteria
and standards in the future. And so we are very excited about the prospects of the work that
you will do over the next several days of the conference.
I am particularly interested and glad to be here to talk to you about the special emphasis that
this Administration, the Clinton-Gore, Administration is placing on the importance of clean
water. We believe that water, clean water protection of our water resources is one of the
most important tasks, very important responsibilities that we have. Water is essential to our
health, our economy and to our natural world. It is the first line of defense, the most
fundamental line against environmental threats to human health. Clean water, and I think this
is relatively simple but is worth restating, keeps our communities healthy and thriving, it
creates jobs and tax revenues across this our country. It nourishes our farmlands. It sustains
the animals for which we share our world. If you look at what we have been able to
accomplish in the EPA and the state and local agencies that share in this work with us, over
the last 25 years, we have been very successful in many ways. We have accomplished a lot.
But if you look at the challenges that lie ahead, they are great. So despite our progress much
remains to be done. Forty percent of the rivers, lakes and streams in this country today do
not meet standards, and are still too polluted for fishing and swimming. Now you all know
that in some ways far better than I. Last year the states issued 1000 fish consumption
advisories, warning people not to eat the fish in specific rivers, lakes and streams. In the city
of Milwaukee 100 people died from their tap water that came from the lake. The lake that
provided the drinking water for the people of Milwaukee was contaminated. Hundreds of
thousands became ill and 100 people died. And today, a year and half later there are still
people suffering in Milwaukee because of that contamination.
New York and Washington, DC in the last year experienced problems, crises in their drinking
water supplies, associated with contamination of their source water. In addition to the
pollution problems, the contamination problems that we are facing and that our water faces,
there is another threat and that is a political threat. Now while many citizens, businesses.
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Browner
public officials across the country are working harder than ever before to solve environmental
problems, there are a few but a vocal few who call for a rollback in the progress we have
made, who seek to challenge the safeguards that we have worked so hard to put in place.
Unfortunately, they are very good at using stories, horror stories to advance their argument
on why environmental standards have become too rigid, ridiculous in their words.
Now some of you may have heard the story about drinking water, that is commonly told these
days, how EPA requires all of the states to test for the pineapple pesticide. Now isn't this
ridiculous. We are requiring people to test for pesticides, the. pineapple pesticide that was
only used on pineapples. And since pineapples are not grown in most of our states, why are
we doing this? The truth is that this particular pesticide was used in most all of our states.
It was used on broccoli, peas, carrots, and lots of crops. And unfortunately, it continues to
be found in drinking water supplies 13 years after EPA banned the use of this pesticide.
We banned the use of it because it was found to have significant health effects, including
male sterility. So I don't think what we are doing is silly, or ridiculous, but that is how this
one standard, this one requirement has been portrayed to the people of this country. And
because of that story, there are now people is Congress who think we should weaken the
drinking water standards, rather than strengthen the drinking water standards.
If we are going to be able to address the very real environmental problems we have in this
country, and the political arguments that we are encountering far too frequently, then we
believe, this administration, the Clinton-Gore Administration, believe that we must launch a
new generation of environmental protection. One that is based on a firm commitment to the
goal of environmental protection to tough standards. Standards designed to protect those
most at risk-children in many instances. But standards that are combined with flexibility,
innovation and common sense and how they are implemented. Goals that are combined with
common sense, innovation and flexibility and how they are achieved.
This new generation of environmental protection should be based on three simple principles.
First, we must recognize that nature is a system. Too often the past approach has been a
piece- meal approach and the result of this piece-meal approach has been to shift pollution to
move it from our air to our water to our land rather than reducing and preventing pollution.
Instead of continuing to simply shift pollution, we must take a comprehensive approach. Now
in the case of water this means a watershed approach. It means looking at an entire system.
At the tributaries, at all of the pieces that make up a functioning ecosystem, a watershed.
It means dealing with the non-point sources, as well as the point sources. It means dealing
in a holistic manner instead of simply focusing on an individual segment one after the other.
The second principle is pollution prevention, instead of waiting to clean up the pollution, we
must prevent pollution. Instead of waiting to filter the water that becomes our drinking
water, treat the contamination. Why not prevent the contamination from entering the source
water. Why not protect the sources of our drinking water. When I go out and talk to the
public about this concept, they are shocked that anyone would oppose it, that anyone would
oppose the source water protection in the drinking water program. And yet in the debate in
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Browner
Water Quality Criteria and Standards for the 21st Century
Congress over reauthorization of the drinking water law, this has been one of the hardest
issues for us to secure the votes necessary to change the law.
The third principle is we must seek to involve those who must live with the decisions that we
make. Those people include the business community, citizens, states and local government.
They must have every opportunity to work with us in making our decisions. In place of a one-
size-fits-all approach, we must recognize that there are local differences.
Now I come from Florida. I grew up there. I spent a lot of time working on environmental
issues in that state. While there are similarities in the environmental problems that Florida
faces with California, even Maine, maybe Alaska, there are very real differences, and we must
able and willing to recognize those differences and find solutions that speak to those
differences. I'm sure that each and every one of you coming from your community, your
state, is familiar with the differences in your state that need to be addressed that can allow
for the kind of change, for the kind of solutions that we all want, and that we all know are
so necessary.
In my experience of working with local communities and informing and involving them in
making environmental decisions, I have always found that a local community once informed
and involved will be willing to make far more difficult, far more stringent decisions than a
distant bureaucracy, than a governmental agency can make. We are forced to look at
everyone simultaneously. A local community can look at itself and make appropriate
decisions. And yes, they will be different from a decision that another community will make.
A decision about how to protect one watershed will be different than a decision to protect
another watershed, because they are fundamentally different systems. We must allow for and
create the mechanisms to recognize those differences and to build our solutions around those
differences.
So what we are doing in this Administration is taking these three principles and fighting to
change the programs, to change the laws on Capitol Hill. We are asking Congress in effect
to write these principles into the Clean Water Act, the Safe Drinking Water Act, and
Superfund. To change the laws so that they embody a fundamentally new approach to water
protection that will work for all people in all communities.
Now I spoke briefly about the Safe Drinking Water Act. We believe that it is very important
to strengthen the Safe Drinking Water Act. We believe that it is important to allow EPA and
the states to work together to decide what are the most dangerous contaminates around
which we should be setting standards for.
We believe the enforcement provisions of the Safe Drinking Water Act should be strengthened
so that the bureaucratic hoops that we must now jump through before we can take an action,
are removed and when there is a problem we can act expeditiously to ensure safe drinking
water. We .believe that we should provide money to the states in the same way that the
states have received money for clean water implementation over the last two decades. We
believe there should be federal money to the states to assist them in their work of providing
safe drinking water. And finally, and I think in many ways most importantly for the long term,
is we must achieve source protection.
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Browner
We need to see the law changed so that communities who are willing to invest in protecting
the source water have that flexibility. So that if they are willing to take dollars that would go
towards treatment and put those dollars upstream to prevent the pollution, that they can
make that long-term decision for their citizens, for their community.
Now we are hopeful that this will pass. It has passed in the Senate, and the House is literally
working around the clock to achieve a strong reauthorized Safe Drinking Water Act. As many
of you are aware we also asked Congress to reauthorize the Clean Water Act. We thought
that there were important changes if we were to do the job that we know must be done to
protect the rivers, lakes and streams of this country. We asked that a new Clean Water Act
include incentives for watershed planning so that states could look on a watershed basis,
could work on a watershed basis. We asked Congress to give us the tools and the states the
tools to address polluted runoff, to improve our approach to stormwater problems, combined
sewer overflow and again to provide federal dollars to the states.
Now 1 don't think anyone believes that it is possible that we will see a reauthorized Clean
Water Act this year. And obviously we are disappointed. As of last night the money will be
available to the states despite the fact that there will not be a reauthorization. But we believe
that even without a reauthorization there is an awful lot that we can do within the existing
law. And so in the coming months we will be looking at what tools are available to us to
address the problems of non-point source pollution, to encourage watershed protection, to
address storm water runoff and combine sewer overflow. We will be looking at how we in
conjunction with states and local governments can move forward to achieve real watershed
protection.
We also have several initiatives within the agency that will change how we do this job of
protecting our environment in this new generation of environmental protection. Let me briefly
mention one of them to you and that is our common sense initiative. We have selected six
industries that we will be working with on an industry-by-industry basis rather than a
pollutant-by-pollutant basis. As we look at the history of our work over the last two and half
decades, what we see is that the strides we have been made on a pollutant-by-pollutant basis
while significant, are not ever going to be fast enough and of the magnitude necessary to
address the kind of problems that we are seeing. And so, instead, we need to work on an
industry-by-industry basis to achieve pollution prevention for example, to discover how the
printers could best implement pollution prevention. And the answer to the printer will be
different than for the people who paint automobiles, or for the people who make electronic
equipment.
So we will be working with the six industries, environmentalists, and state regulators to
design a blueprint for environmental protection, pollution prevention, and compliance. It is our
hope that as we move forward in these industries we will be able to add other industries in
the coming months and years.
We are also moving ahead with a fundamentally new approach to water quality standards.
The public, industry, and environmentalists I think are all demanding, and you know this far
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Browner
Water Quality Criteria and Standards for the 21st Century
better than I that we must develop new tools that will more accurately measure the health of
our rivers, our lakes and streams. I think there is a growing recognition that the old tools are
not enough, that the chemical-by-chemical approach is not enough. The old tools don't do
a good enough job of measuring the combined effect of a variety of chemicals.
In some ways it is as if when we look at a specific chemical we have blinders to the other
problems. And then we look at another chemical and we have blinders to what we saw
previously. The current tools, the old tools aren't enough to deal with sediment in the water.
They aren't enough to really measure whether our water bodies are suitable for fishing,
swimming, supporting wildlife, and the balance, the diversity so important to maintaining a
healthy ecosystem. The old tools are not enough to ensure that we are dealing with all
sources of water pollution. They are pretty good in terms of the industrial pipe discharges,
but I don't think that any of us believe they are adequate or what they should be for dealing
with the other sources of contaminants.
So for all of these reasons we need new tools. And we are working today at EPA to develop
new tools that will serve the communities of this country, that will serve you all as we work
together to implement Clean Water Act criteria and standards program, as we seek to fully
develop and implement that program.
We are working to develop biological criteria, sediment quality criteria, wildlife criteria, and
new methods for evaluating risks as it effects both human health, and the health of our
environment. We must be looking at both. If we are successful in the efforts to develop
these tools, these approaches, then we will be successful in our efforts to move beyond the
chemical-by-chemical approach of the past.
So if there is one thing I would like to leave you with as you begin this conference, it is quite
simply this. We need to hear from you. We need to know what are the tools you need in the
work that you do. What are the tools that you have developed that perhaps can be used in
other parts of the country. And we need to all continue our efforts to work together, at the
federal level, the state level, local level, environmental level, and industry community so that
we can make the new generation of environmental protection a reality. So that we can
recognize that our natural world functions as a system. So that we can prevent pollution,
rather than continue to clean up pollution and so that we can allow those who must live with
our decisions, who must implement our decisions to be a part of making those decisions.
I have no doubt that the discussions that you will engage in over the next several days will
help to advance these goals, and most importantly will help all of us in our efforts to leave a
legacy of clean water for our children and our children's children.
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Water Quality Criteria and Standards for the 21st Century
Tudor T. Davies
Director, Office of Science and Technology
U.S. EPA
Introduction of Margaret Stasikowski
What we are going to do now is have Margaret Stasikowski, who is the Director of the Office
of Health and Ecological Criteria Division in OST give you a little background to the conference
and an overview of the topics and the themes we would like to cover over the next couple
of days.
As I said in my welcoming remarks, we expect you to be strong participants. We are trying
to get a variety of view points and perspectives for each of the topics we've chosen to cover,
and we would like dialogue. If you don't get an opportunity to speak, I think that if you have
some biding concern please put them in writing and send it to us. And, we will try to
incorporate those ideas if they don't get incorporated.
And then on the last day my staff and I will get together and I will try and to summarize what
we think we have heard and what we will try to do as a result of the conference.
At this point I would like to introduce Margaret Stasikowski who will give you the overview.
When she is finished we will take a break and then we'll get directly into the proceedings of
the conference.
Thank you. _
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Stasikowski
Water Quality Criteria and Standards for the 21st Century
CONFERENCE INTRODUCTION
Margaret Stasikowski
Director, Health and Ecological Criteria Division, OST
U.S. EPA
Good morning. I would like to add my welcome to that of Administrator Browner and Dr.
Davies. We have a very full program for you over the next three days and I think you will
find the program both interesting and challenging. The administrator has talked about the need
for a comprehensive approach in dealing with environmental problems. She has described the
environment as a system that requires an integrated approach to pollution prevention and
control. This conference focuses on these needs and will attempt to point the way to the
development of new concepts and tools for addressing ecosystem issues in watersheds. I will
give you a brief summary of my presentation. We will talk about the purpose of the
conference, provide you with some historical context for where we are in the clean water
programs, talk about specific objectives of the conference, and give you an agenda for the
next three days, emphasizing the critical points of each of the technical sessions.
Over the last few years at EPA and perhaps longer in the states, we realized that to continue
to make progress in cleaning up our nation's waters, we need to emphasize watersheds as
entities to be assessed and managed. Many of our scientific, technical and implementation
tools, however, have been built for a program that placed emphasis on control of industrial
discharges. The purpose of our conference is to describe the programs that we need to
support the watershed based management of ecosystems. At the conference we will discuss
with you the scientific tools that are needed to assess and manage the quality of ecosystems
in watersheds. We will provide examples of how watershed based assessment and
management can be done. I am sure these examples will be a forum for lively debates. The
new science has no value unless it is used. Perhaps most importantly we want to talk with
you about how to implement the new approaches and how to integrate them with our existing
programs. We want your thoughts on how to include you the stakeholders when we develop
guidance for assessment and management of ecosystems in watersheds.
Whenever I think about where the water quality programs, or for that matter any
environmental program is, I find it useful to put it in its historical context. We can argue how
far we need to go back, let's just say go back about 40 years to the time when environmental
concerns rarely made the first page of the newspaper.
Appropriately, the focus of our early programs was to reduce the point source industrial
discharges. These programs, as the Administrator has said, were largely successful.
Together we have accomplished a lot. You cannot set rivers on fire anymore. Fish have come
back to many of our water bodies, i understand that the Potomac River, for example, is one
of the best places for bass fishing on the East Coast. Certainly that was not true 30-40 years
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Stasikowski
ago. There are many stories of progress that we have made with technology-based and water
quality-based programs. As we collect information about the environmental releases of
chemicals, data sources like the Toxics Releases Inventory, show us that mass loadings of
individual chemicals have been drastically reduced. And, as I have already mentioned, there
are many signs of improvement. Each of you I am sure knows of successes that have
occurred over the last 30 years. So far I talked about point source discharges of chemical
pollutants, yet when you look at the objectives of the Clean Water Act they include chemical,
biological and physical integrity and protection of human and ecological resources. We have
not stopped ecological degradation of the watersheds. But that's not surprising because
watershed quality depends on many influences beyond point source discharges of chemical
pollutants.
Some of those influences are nutrients/over-enrichment, habitat degradation, alteration of
water quantity and flow, and sedimentation. Non-point sources of pollutants are very
important. How all of these influences interact and which one may be a key to degradation
of an ecosystem is an important reason for us to move into watershed based assessment and
management. To accomplish the objectives of the Clean Water Act, we must solve problems
on the watershed level. Some of the assessment tools that we've developed in the past 20
years will need to be modified when we apply them to make assessment and management
decisions in specific watersheds. There is a need for new tools that we do not have, and
there is a need for implementation programs that may be somewhat different from what we
have today.
So before we go to the agenda of the conference what are the objectives for the conference?
We want to share with you the methods that we have under development to measure effects,
and distribution of chemical, physical, and biological stressors on a watershed. We are going
to discuss with you how these methods can be used in assessment of watersheds to examine
impacts from multiple stressors to identify the relative importance of various stressors and
how to identify key stressors for a specific watershed. We will discuss and seek your input
on how watershed level assessment can be applied within our current laws, and how to
implement effective watershed management.
CONFERENCE AGENDA
In the first session we will cover chemical pollutants commonly referred to as toxics, and how
the program has and will continue to change in this area. For many reasons we have in the
past concentrated on development of chemical criteria to protect human health and aquatic
life in the water column. We're making a shift to develop criteria based on the transport and
fate of pollutants. Even though past criteria have been specific numerical values, the science
that supports them is not that precise. We want to and we will discuss with you some
innovative approaches under development to deal with that imprecision. We will prioritize
development of criteria to address the chemicals that pose the greatest risk to an ecosystem.
We'll discuss development of criteria for those parts of the ecosystem most at risk. But we
must move beyond chemical toxicity to address ecosystems in watersheds. You'll have an
opportunity to explore that in our second session. Some of the key issues that we will cover
during that session are:
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Stasikowski
Water Quality Criteria and Standards for the 21st Century
Biological information can be an indicator of the condition of an aquatic ecosystem. This is
the session where we will talk about the tools that are needed to address nutrients/over
enrichment, habitat degradation, sedimentation, alteration of water quantity and flow. We
will discuss how these tools differ from our traditional water quality criteria.
The third session is a link between development of tools to address individual problems and
solving the right problems in the watershed. Most likely when addressing issues in the
watershed one is looking at the complex situation. In this session we will describe what
watershed ecological risk assessments are and we will have some examples of those. We will
discuss the value of ecological risk assessments in understanding watershed problems. We
will be addressing some complex issues, for example, endangered species. Ecological risk
assessment methods can promote better watershed management. We will describe how that
can be true.
Session four will be very interesting for many of you, it is where the rubber meets the road.
How can these ideas be implemented by states? What will the state programs of the future
look like? Well, we will discuss what a comprehensive state water management program may
look like in the future. We know that to accomplish the many different objectives of a
watershed management program, the definition of what a state program is may need to be
broadened. We will also discuss whether and how much flexibility we already have in
interpretation of current laws and policies.
But of course we have been conducting watershed assessment and management for some
time already. It's actually through the use of those assessments that we learn what additional
tools we need, and how critical it is to address ecosystem problems based on the watershed
basis.
In our last technical session, session five, we will discuss how a watershed approach to risk
management has been and is being used currently. We will describe how to use the tools we
have and how future guidance will help to continue watershed protection. There will be a
discussion of how important site-specific planning is to a successful watershed management
activity.
At the end of our conference we will have a summary session with Dr. Davies. We will have
a stakeholders session chaired by Dr. Southerland where we are looking forward to summaries
of the sessions and your recommendations to us.
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I I
1
Session 1
New Ways
To Evaluate Risk:
Moving Beyond Chemical
Toxicity in the Water Column
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Session I
Water Quality and Standards for the 21st Century
NEW WAYS TO EVALUATE RISK: MOVING BEYOND CHEMICAL
TOXICITY IN THE WATER COLUMN
Amy L. Leaberry
Health and Ecological Criteria Division
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
Session Manager
Abstract: This session covers background on the traditional Criteria—Standards—TMDL—
Permits—Enforcement approach to water quality protection and how it is evolving to address
the dispersion of contaminants through different media: water, sediments, air, and tissue.
The session provides information on how criteria can be used to address effects from
pollutants in media other than the water column and provides approaches on how to use
criteria to solve environmental problems. The session will include a review of the
environmental gains and benefits of chemical water quality criteria achieved to date and gives
insight on how chemical water quality criteria may be developed and applied in the future.
SUMMARY
Introduction
This session explains the background of traditional water quality criteria and how the criteria
are evolving to address multi-media stresses
Criteria that are used to assess water quality now or will be used in the future include:
human health criteria
aquatic health criteria
sediment criteria
wildlife health criteria
The panel for Session 1 will discuss EPA's long term water quality goals. The panel includes
representatives from the following:
state agencies
industry
environmental groups
The panel will give recommendations on EPA's future direction on water quality criteria.
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Session I
Discussion
EPA's long-term goals and future directions
Toxics criteria and assessment tools
move beyond water column toxicity
Historical criteria
mainly concerned with water column toxicity
limited to two criteria - human health and aquatic life criteria
New direction - branch off to other areas where pollutants occur and cause effects
Improve existing Aquatic Life assessment methods
Improve existing Human Health assessment methods
New assessment methods:
sediment
wildlife
bioaccumulation
nutrient criteria
Goals of EPA
Maximize protection of aquatic dependent resources
Develop and apply most appropriate tools to implement an integrated watershed
approach
Emphasize areas that will allow us to achieve greatest environment benefit
Toxics Strategy
determine areas of impairment
known impacts and effects
integrate effects information
use tools to evaluate
Pollutant analysis
mode of action + route of exposure — > fate and effects
must be conducted across media
must identify all risks and effects
adapt tools to address risk
define adverse impact based on exposure to populations
ex. Great Lakes - didn't pay enough attention to biological effects focused on
reducing chemicals rather than achieving a desired goal.
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Session I Water Quality and Standards for the 21st Century
may be better for EPA to specify ranges or procedures instead of hard/fast criteria.
Need to be innovative in methods development. Lab methods do not necessarily
predict Field conditions or deliver exact effect information.
Integration and development:
Study interrelationships between water, sediments, food chains
This will allow EPA to avoid setting standards that overlap and avoid gaps in criteria
Look for potential for greatest environmental benefit
Consider resources needed to develop criteria to provide economically effective
standards
Environmental gains can be made without all the information, so proceed forward with
the information that is available, considering the uncertainties associated with the
(amount or type) of data collected.
EPA Future Direction
Disinvestment:
mass production of criteria - instead, focus on key (those posing greatest risk)
pollutants
non-integrated criteria (i.e. studying effects on aquatic health in absence of
consideration of human health, wildlife, etc.
Investment:
Integrated assessments/approach
Methodology development
Leverage resources to impact major environment problems in order to
gain the greatest impact with available resources
Are current resources being used in the most effective way?
Should methods being developed be more simplified?
What role do states, tribes, etc. play?
Current methodology may be too resource intensive for states/tribes to use without
EPA assistance
Consider simplifying current methods if to be utilized by States alone.
Methodology development
future areas of emphasis:
chemical exposure analysis - across media
plant toxicity
bioaccumulation models/predictions
nutrients - beyond chemical aspects
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Session I
New Ways to Evaluate Risk
assess true fate and effects of pollutants
innovative application of data to create tools
integration to increase utility of toxics criteria
More stakeholder participation
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Session I
Water Quality and Standards for the 21st Century
A DIFFERENT FOCUS FOR THE SCIENCE BEHIND CRITERIA
James J. Reisa, Ph.D.Director
Environmental Studies and Toxicology
National Research Council
Washington, DC
Abstract: New concepts and methods for assessing the risks that environmental toxicants
pose to human health and ecological resources are needed, inevitable, and rapidly evolving.
Although toxicological risk assessment is still an immature field of applied scientific practice,
the enormous demand for such information brings impatient scrutiny and pressure for
improvement, ready or not. Only a decade since the "red book" paradigm for risk assessment
was proposed, revolutionary changes are underway on several fronts. Deficiencies in current
risk assessment practices concerning default assumptions, uncertainty, and variability have
been identified and are beginning to be addressed by EPA, Congress, and risk assessment
practitioners. Efforts are also underway to remedy past overemphasis of human cancer risks;
more robust and more effective approaches are being pursued in reproductive and
developmental toxicology, neurotoxicology, immunotoxicology, and ecotoxicology. Within this
context, some of the most important challenges and opportunities in risk assessment today
are being posed by the group of phenomena associated with xenoestrogens and other
hormone-related toxicants—sometimes called "endocrine disrupters"—in the environment.
Various pesticides and industrial chemicals-especially certain persistent, bioaccumulating
organohalogens—have been reported or suggested to produce reproductive impairment and
developmental abnormalities in wildlife and a variety of developmental and other adverse
health effects in humans through alterations of hormonal homeostasis. The need to
understand and address these phenomena is likely to force development of new and more
sophisticated risk assessment approaches with respect to elucidating toxicological and
pharmacokinetic mechanisms, defining adverse effect "end points", integrating human health
and ecological risk assessments, assessing multiple chemical exposures, and assessing
environmental loading, transport, fate, ecological comparmentalization, and exposure
pathways for environmental toxicants. These challenges potentially represent great
opportunities for improving both risk assessment and regulatory practices.
Summary
EPA Office of Water is currently funding research in human and environmental effects of
xenobiotics
NRC looking at new ways to evaluate risk
30 years ago there was no risk assessment
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Session I
Only 11 years since development of Red book
Applied science struggles to attain creditability
Concerns expressed about risk assessment methods developed by EPA
Criticisms of EPA Risk Assessments:
Anti-regulatory: EPA is overregulating with overprotective results.
Multiple overprotective assumptions lead to over simplified results
Inflexible: resists scientific evidence unresponsive to additional scientific evidence
believe that uncertainty leads to excessive regulation of trivial risks.
Pro-regulatory:
insufficient attention to non-cancer health effects
risk assessment looks at one chemical at a time
should look at multiple effects
population variability
sensitivity of people tested should be looked at
less susceptive animals being looked at instead
ploys to delay regulations
scientific priesthood vs. public opinion
Risk assessment is still young, incorporated in many of the statutes
There is a strong movement to use risk assessment to comparatively rank regulatory
initiatives
Last three EPA administrators moved forward to use risk assessment
National Research Council - not a government agency
serves as an advisor to government in scientific matters
strategically seeks to help advance scientific methods that help to assist public
decision-making
NRC looking at:
biological markers
exposure assessment reports
variability of toxic effects - pesticides if diet of babies and children who are not
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Session I
Water Quality and Standards for the 21st Century
little adults, (physiology is different)
issues in risk assessment
paradigm for ecological risk assessments
applicability of carcinogenic risk assessment to ecological risk assessment
most important research to date was to evaluate EPA Red book risk assessment
Report: "Science and Judgment in Risk Assessment"
Looked at Red book paradigm
Risk assessment assumptions should be standardized
Recommended to EPA:
Document default options and assumptions
Document basis for arriving at an assumption and basis for departing from default
Continue using them
Need to stop cookie cutter assessment
process needs to be iterative to increase confidence - feedback to research to
decrease uncertainty
Conduct formal uncertainty analyses
Science Policy Council presented plans for Agency to adopt recommendations of report
Xenobiotic Chemicals
mimic hormones and have important effects on developing organisms
affect all animals
masculinization
feminization
cancers, ectopic pregnancies
literature mostly anecdotal and speculative
no exposure assessment of endocrine disrupters
NRC will do a critical literature review
NRC will develop conceptual framework for looking at Xenobiotics
Beyond importance of toxic effects they see study of Xenobiotic toxicants as a
challenge to:
advance risk assessment methods
look at toxicologic/pharmokenetic mechanisms
study adverse effect end-points
address human/ecological risk assessment
study multiple chemical exposures
study transport/fate/ecological compartmentalization
Move away from traditional water quality column criteria
1-7
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Report of the EPA Science Policy Council
on the National Research Council Report
"Science & Judgment in Risk Assessment"
May 31, 1994
"The NRC report contains a comprehensive analysis of
the state of the science of cancer-risk assessment and
its uses in relation to decision-making at EPA."
"The SPC agrees with the general course of action that
the NRC advocates. In particular, we view the 70
recommendations, taken together, as providing a sound
conceptual framework for our continuing efforts to
upgrade health-risk assessments (ie, both cancer and
non-cancer hazards), strengthen the linkages between
risk assessment and risk management, and improve the
ways EPA communicates about risk with all interested
parties."
"The recommendations cover a wide variety of objectives
from near-term methodological refinements to long-term
research. Although some of the recommendations can
be implemented in the short term, a comprehensive
response will require a sustained resource-intensive
effort for the forseeable future."
"The SPC believes that the combination of the NRC
report and our proposed response constitute a realistic,
multifaceted approach to improving both our capability
for health-risk assessment and its applications in support
of environmental protection."
-------
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Toxicologic/Pharmacokinetic Mechanisms
Adverse Effect "End Points"
Human/Ecological Risk Assessment
Multiple Chemical Exposures
Transport/Fate/Compartmentalization
-------
Session 1
Water Quality and Standards for the 21st Century
CRITERIA DEVELOPMENT PAST, PRESENT, AND FUTURE
New Ways to Evaluate Risk: Moving Beyond Chemical Toxicity in the Water Column
Morris Flexner
Environmental Scientist
Water Management Division
U.S. EPA, Region 4
Atlanta, GA
The Water Quality-Based Approach in EPA Region 4:
Recommendations
Environmental Gains, Barriers and
"It is the mark of an instructed mind to rest easy with the degree of precision which the nature
of the subject permits and not to seek an exactness where only an approximation of the truth
is possible."
- Aristotle -
Background
During the past two decades, we have succeeded in reducing some forms of serious water
pollution, especially from point sources (e.g., factories and sewage treatment plants)[Adler,
1993]. The Clean Water Act (CWA) was an appropriate law for responding to disasters like
the burning of the Cuyahoga River in the summer of 1969. However, separate laws for
water, air and land often shuffle pollution from air to water and from water to land instead of
preventing it[Browner, 1994].
Also during the last two decades, the EPA has developed water quality aquatic life and human
health criteria for nearly 200 chemical entities and substances. The specific value for each
substance adopted by EPA was based upon exhaustive examination of the existing scientific
literature and knowledge of the particular chemical entity [EPA, 1992]. These criteria are the
foundation for water quality-based control in NPDES permits.
Despite the progress that has been made in the area of criteria development for chemical
toxicity in ambient waters and point source pollution control, there are over 65,000 chemicals
registered for current use in the United States, with new ones added continuously. Many of
these chemicals are released into the environment by discharges into air, water, sewer
systems, land or subsurface. More than 1000 of these chemicals have been identified in the
waters of the Great Lakes [EPA, 1992].
Although the number of registered chemicals and types of chemicals found in surface waters
continue to increase each year, the number of water quality criteria published by EPA over the
last fifteen years have remained virtually unchanged. For example, the number of aquatic life
chronic criteria for priority and non-priority pollutants with published criteria documents has
1-9
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Session I
only increased from 28 criteria in 1980 to 36 criteria in 1994 [EPA, 1982; Wagener, personal
communication, 1994]. While the number of aquatic life criteria has remained relatively
constant, the number of aquatic species used in data bases to support the criteria derivations
has almost doubled from 99 in 1980 to 188 in 1994 [EPA, 1982; Wagener, personal
communication, 1994]. Thus, the criteria that are in use today have been thoroughly
researched but their development cannot keep pace with the growth of the chemical industry
and when applied alone may not adequately protect aquatic and human health resources. If
we are ever to achieve the CWA goal of restoring, protecting and maintaining the chemical,
physical and biological integrity of the nation's waters, we must look beyond chemical toxicity
in the water column alone to other appropriate water quality and ecosystem health measures.
Environmental Gains
Many of the gains in point source pollution control can be attributed to the water quality
criteria and NPDES programs. At the regional level, we can examine progress that has been
made through the implementation of aquatic life and human health criteria to control the
potent carcinogen, dioxin. The adoption of water quality criteria for dioxin (2,3,7,8-TCDD)
is an example of environmental gains that have resulted in Region IV at least partly from the
implementation of these criteria. To date, 97% (37/38) of the bleach kraft mills in Region IV
comply with State water quality standards for dioxin. In 1990, 30 mills in the Region
discharged detectable levels of dioxin. Today, only 12 mills (30 %) discharge detectable
levels of dioxin.
Correspondingly, fish consumption advisories for dioxin in Region IV have also decreased. In
1990 there were 13 advisories for dioxin in six of the Region IV States [AL(3), FL(2), MS(1),
NC(5), SC(1), & TN(1)]. Today there are only 5 advisories for dioxin in four Region IV States
[FL (1) MS (1), NC (2) and TN (1)]. Nationally, 22 States have fish advisories for dioxin.
Despite this apparent progress, questions remain about endocrine, immunologic and
reproductive effects that may be occurring at dioxin levels below analytical detection.
Other factors to consider when comparing fish consumption advisory information within a
region or across the country include: 1) the procedures that States use to remove a fish
consumption advisory can vary from State to State (some require several years worth of data
to lift a ban whereas others may remove a ban after a single season of data collection), and
2) the source of the pollution responsible for the advisory may come wholly or in-part from
an adjoining State.
Barriers to Meeting Clean Water Act Goals
In many respects we are actually losing ground in our efforts to restore aquatic, ecosystem
health. This problem is primarily due to massive pollution running off of farms, city streets
and other intensive land uses (known as nonpoint source pollution or polluted runoff) coupled
with large-scale destruction of wetlands, floodplains, stream channels, and other important
aquatic habitat[Adler, 1993]. Without additional tools and resources, controlling runoff
pollution will remain one of the nation's most formidable water quality challenges. Barriers
to achieving results have included inadequate or incorrectly installed BMPs, the lack of
1-10
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Session I
Water Quality and Standards for the 21st Century
biological criteria habitat criteria, nutrient criteria (including chl a criteria for lakes), wildlife
criteria, sediment quality criteria, and endangered/threatened species criteria.
To overcome these barriers, we must release the shackles of single-media, pollutant-by-
pollutant "tunnel vision," and embrace existing multi-media and pollution prevention
alternatives. As a step in this direction, Region IV developed a multi-media screening
inspection checklist for inspections in April, 1993. This checklist is required for at least 25%
of the Region's inspections. Yet, coordinated inspections are only a first step because water
, quality problems are often complex and many require detailed assessments that go beyond
the examination of chemical toxicity in the water column and extend into our air and land.
For example, in the 1992 EPA Great Waters Program Report mean concentrations of PCBs,
dieldrin, dioxin (all isomers), DDT, chlordane, and mercury in rainfall were reported at levels
above EPA water quality criteria. For PCBs, DDT and dioxin respectively, the mean
concentrations in rain were 2-3 orders of magnitude greater than the human health
criteriafEisenreich and Strachan, 1992; refer to table in the attached handouts]. This
information clearly indicates the need for multi-media approaches to environmental problem
solving. We need to preserve and strengthen the principles of environmental protection while
changing the means by which we achieve this protection.
Further, the recent development of statewide fish consumption advisories for mercury in
Florida (1993) and South Carolina (1994) demonstrates the role chemical and biological
processes play in adding complexity to a water resources problem[Murphy, 1994 Draft
Report; refer to map in the attached handouts]. To date, at least 30 States are seeing
elevated levels of mercury in fish. Agencies in Florida are currently working with EPA Region
4 on a regional environmental monitoring and assessment program (REMAP) project to
characterize the existing sources of mercury. This information will be distributed to the States
and Tribes as soon as it is available for release.
Other barriers include the overwhelming number of agencies and regulations that we must
engage to address water quality issues. According to a report issued last year by Water
Quality 2000, water quality issues are handled by 18 agencies in seven departments plus
seven independent agencies with 25 separate water programs [Newman, 1993]. By
necessity, environmental regulations have cropped up on an emergency basis, crisis by crisis,
pollutant by pollutant. Today we have 16 major national environmental laws overseen by
some 74 Congressional committees and subcommittees [Browner, 1994]. Too often, our
environmental activities have been compartmentalized, law by law, pollutant by pollutant.
Recommendations for Overcoming Barriers and Implementing Change
We must recognize the integration of our air, water and land. The old way of regulating on
a pollutant-by-pollutant basis is not enough to adequately protect watersheds and
ecosystems.
In Chris Voder's presentation on biological criteria-based experiences in Ohio at the 2nd
National Water Quality Standards Conference held here in Arlington in December 1991, he
1-11
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Session I
provided a flow chart that illustrates in more detail the five major classes of variables
influenced by human actions that impact biology and result in the degradation of water
resourcestYoder, 1991; Karr, 1986]. One of the major findings of Ohio EPA's biological
criteria analysis was the ability of the biota to detect impairment in the absence of chemical
criteria exceedances. In the past, the NPDES program has focused heavily on chemical
variables and flow regime and the related components in Voder's flow chart. The other
variables, however, biotic factors, energy source, and habitat structure have either wholly or
somehow in-part been ignored.
To focus needed attention on these other variables, Karr more recently asked the rhetorical
question, "What is the appropriate balance of mcnitoring approaches?[Karr, 1993]." To
answer that question, EPA's 1990 National Program Guidance for Biological Criteria for
Surface Waters, its 1991 Policy for Integration of Biological Assessments and Criteria in the
Water Quality Program, and rapid bioassessment protocols recommend the three-legged stool
analogy in which the three legs of the stool are the water monitoring approaches (e.g., the
physical/chemical parameters of traditional water chemistry, toxicity testing, and ambient
biomonitoring). In the stool analogy, equal weight is given to each of the criteria. This policy
is often referred to as that of independent application:
Since each type of criteria (biological criteria, chemical-specific criteria, or whole
effluent toxicity evaluations) has different sensitivities and purposes, a criterion may
fail to detect real impairments when used alone. As a result, these methods should
be used together in an integrated water quality assessment, each providing an
independent evaluation of nonattainment of a designated use.
According to Karr, the stool analogy is inadequate. Karr argues his case for a balanced
approach and compares this situation to a tripod supporting a spotting scope. In his words,
"to see a distant bird (or focus on a water resource problem), one must adjust the lengths of
the three legs to accommodate the terrain (or the nature of the water resource problem)[Karr,
1993].
When we consider the additional tools and resources that must be developed by the 21st
century to adequately protect human and ecosystem health, we can imagine the advances
that Karr's spotting scope or tripod analogy will have made. We hopefully will have added
supporting sections to each leg of the tripod so that we can successfully record resource
degradation as it occurs and successfully measure environmental improvements after the
appropriate restoration techniques have been employed. By the 21st century, the water
•chemistry leg of the tripod could include sediment, nutrient and wildlife criteria in addition to
aquatic life and human health criteria. The toxicity testing leg of the tripod could include other
methods for deriving site-specific criteria, including the water-effects ratio (WER). And finally,
the ambient biological monitoring leg of the tripod could and hopefully will include habitat
criteria in addition to the existing narrative and numeric biological criteria for ail aquatic
resource types: streams, lakes, large rivers, estuaries, and wetlands. Each section of the
tripod's three legs would be available to describe the nature of the water resource problem
and also measure the degrees of success in attempting to restore the water resource to a
pristine or least-impacted reference condition.
1-12
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Session I
Water Quality and Standards for the 21st Century
Looking ahead, a watershed protection approach (WPA) that includes basin planning and
permitting, improved effluent guidelines like those proposed for the pulp and paper industry
and those being developed as part of the Administrator's "Common Sense Initiative", and a
strengthened whole effluent toxicity (WET) program coupled with the water quality standards
described above should improve our ability to define problems and evaluate ecosystem health.
For example, EPA's pulp and paper industry proposed effluent guidelines should virtually
eliminate (to detectable levels) all dioxin discharges from industry to water[FR 66078-
66216FR, 1993]. The American Forest and Paper Association has noted the industry's pledge
to cut dioxin emissions to non-detect levels at all US bleach kraft pulp mills by 1996. These
guidelines expect to significantly reduce the discharge of toxic pollutants by 3,000 metric
tons/year and conventional pollutants by 200,000 metric tons/year. The guidelines further
hope to decrease toxic air emissions by 70% of current levels.
This approach will hopefully move us closer to one of the goals of the CWA: zero discharge
of pollutants by 1985. By jointly providing air and water requirements, EPA is promoting
pollution prevention while allowing industry to more effectively plan compliance strategies.
This integrated approach focuses on the multi-media nature of pollution control and allows
each facility to determine the pollution control approaches that should be implemented.
Several States in Region IV have embarked on geographic or "place-based" approaches to
address both point source and nonpoint source inputs into a watershed or river basin. As one
example in Georgia and South Carolina, a comprehensive assessment of water quality
conditions in the Savannah River watershed has been underway since 1990. Recent
discussions with stakeholders in the basin have yielded a comprehensive list of environmental
issues, including:
Fisheries impacts due to poor water quality
Low dissolved oxygen (D.O.) in Savannah River and Estuary
Nonpoint source (NPS) impacts from forestry, agriculture, and urban land use
Sedimentation impacts in estuary yielding navigation problems and increased
dredging
Modification and physical changes in estuary
Point source (PS) discharge impacts
Habitat alteration/destruction
Sediment quality
Urban stormwater impacts on river and estuary systems
A multi-agency/organization effort with stakeholders in the basin is underway to plan and
organize a comprehensive and integrated watershed project that is consistent with the WPA.
Actions are underway to develop a Watershed Management Plan that includes input on priority
actions from all basin stakeholders. There is a great deal of interest in coordinated
management of the natural resources of the Savannah River basin, and the many stakeholders
in the basin are committed to participation in project management, planning and
implementation.
This effort includes the coordination of analyses in the basin by both States, a Regional EMAP
Study evaluating the biological integrity of streams and lakes in the basin, and a use
1-13
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Session I
attainability analysis (UAA) for the Savannah Harbor. The UAA hopes to 1) develop harbor
criteria for protection of the endangered shortnose sturgeon and other estuarine species and
2) develop a dynamic flow, water quality and sediment model to evaluate the effects of
existing stressors, and to also predict the effects of and allocate future pollutant loadings for
Total Maximum Daily Loads (TMDLs).
Section 303(d) of the CWA has resulted in the initiation of over 40 TMDLs in Region 4 (to be
completed by FY 1996), in which the wasteload allocation for point sources and the load
allocation for nonpoint sources for specific stream reaches has been or is being determined.
The TMDL process affords a more holistic, multi-source approach to basin wide permitting.
In the coming years, we must look at how the changes in the way we derive criteria (including
biological and habitat criteria) factor into the TMDL process.
Another approach to addressing the presence of toxic chemicals in toxic amounts that has
gained favor in recent years is the implementation of WET limits in NPDES permits. WET tests
have the advantages of measuring the combined effects of many potentially toxic substances
in an effluent and provide an integrated assessment of the potential toxic effects of effluent
discharges on receiving waters. Some of the other advantages of WET tests are that they
address unknown toxicants through toxicity identification and toxicity reduction evaluations
(TIE/TREs), provide a measure of bioavailability, and can accurately predict impacts to biota.
We need to investigate the application of WET into the criteria and standards programs.
Through 1992, Region 4 States had issued over 1000 NPDES permits with WET limits [Hyatt,
personal communication, 1994]. In 1992 there were about 2500 NPDES permits with WET
limits nationally with about 290 labs conducting the tests [Peltier, personal communication,
19941. North Carolina WET program compliance for industrial facilities and POTWs is
currently about 89% and 91%, respectively [Ausley, personal communication, 1994]. An
important component of any WET program is the proper implementation of a quality
assurance/quality control (QA/QC) program in which an unknown toxicant is sent to
laboratories for testing with each species used in their toxicity program. Companion to
QA/QC procedures is a commercial laboratory certification process. EPA currently has no
commercial laboratory certification process. However, some States do have lab certifications
and a fee is charged.
Finally, despite attempts to meet the goals of the CWA for over 20 years, we still have a long
way to go. Although the failures of the CWA outweigh the handful of successes, we must
"never give up" and remain committed to restoring the chemical, physical and biological
integrity of the nations waters with improved water quality tools and approaches that we
must continue to refine into the 21st century.
Acknowledgements
The author acknowledges the following folks, without whose help and support this
presentation and paper would not have been possible: The Region 4 Water Quality Standards
Section (Lydia Dow, Joel Hansel, Jim Harrison, Keeva Lloyd, Edyth McClusky, Fritz Wagener,
and Eve Zimmerman), Meredith Anderson, Jim Greenfield, Marshall Hyatt, Amy Leaberry, Bill
1-14
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Session I
Water Quality and Standards for the 21st Century
Peltier, Larry Ausley, Dan Scheldt, Karrie-Jo Shell, Dee Stewart, Allan Antley, and last but not
least, Mike McGhee.
References Cited
Adler, R.W., Landman, J.C. and D.M. Cameron. 1993. The Clean
Water Act, 20 Years Later, Island Press, Washington, D.C.
Browner, C.M. 1994. The Common Sense Initiative: A New
Generation of Environmental Protection, Center for National
Policy Newsmaker Luncheon, USEPA, Office of Communications,
Education and Public Affairs.
Eisenreich, S.J. and Strachan, W.M.J. 1992. Estimating
Atmospheric Deposition of Toxic Substances to the Great
Lakes. Workshop Proceedings, Canada Centre for Inland Waters, Burlington, Ontario,
Canada, January 31-February 2, 1992.
Karr, J.R. et al. 1986. Assessing Biological Integrity in Running
Waters: A Method and its Rationale. III. Nat. Hist. Surv. Spec. Publ. 5. Urbana.
Karr, J.R. 1993. Defining and Assessing Ecological Integrity:
Beyond Water Quality. Environmental Toxicology and Chemistry, Vol. 12, pp. 1521-
1531.
Murphy, P. and T. Stiber. 1994 Draft. Region IV Fish Advisories. Environmental Services
Division, Athens, GA.
Newman, A. 1993. A Blueprint for Water Quality. Environ. Sci.
Technol., Vol. 27, No. 2.
Plafkin, J.L., M.T. Barbour, K.D. Porter, S.K. Gross and R.M. Hughes. 1989. Rapid
Bioassessment Protocols for Use in Streams and Rivers, Benthic Macroinvertebrates and Fish.
EPA 440-4-89-001. Office of Water Regulations and Standards, USEPA, Washington, D.C.
USEPA, 1993. 40 CFR Parts 63 and 430. Effluent Limitations
Guidelines, Pretreatment Standards, and New Source Performance Standards: Pulp,
Paper and Paperboard Category; National Emission Standards for Hazardous Air
Pollutants for Source Category: Pulp and Paper Production; Proposed Rule. FR 66078-
66216, December 17, 1993.
USEPA, 1992. Chapter 2.2., Exposure and Effects of Airborne
Contamination for the Great Waters Program Report.
USEPA, 1991. Policy for Integration of Biological Assessments and Criteria in the Water
Quality Program. USEPA, Office of Science and Technology, Washington, D.C.
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Session I
USEPA, 1982. Recalculation of State Toxic Criteria, Office of
Water, Standards and Applied Sciences Division, Washington, D.C.
Yoder, C.O. 1991. Answering Some Concerns About Biological
Criteria Based on Experiences in Ohio. Pages 95-104 in Proc. Water Qual. Stand. 21st
Century, USEPA, Office of Water, Standards and Applied Sciences Division, Office of
Science and Technology, Washington, D.C.
1-16
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Water Quality and Standards for the 21st Century
FROM SOURCES TO FATE AND EFFECTS: AN INTEGRATED APPROACH
TO MERCURY CONTROL
Edward B. Swain
Research Scientist
Minnesota Pollution Control Agency
St. Paul, MN
Abstract: It is entirely possible for all point discharges to meet the EPA criterion for mercury
but for the water body to yield fish that exceed fish consumption advisories. The EPA
mercury criterion is outdated in light of recent data and is too high at 12 ng/L. The current
national criterion does not account for food chain sources of mercury, which are now thought
to be the main source of mercury to fish. Certainly some lakes that have ambient levels of
only 1 to 2 ng/L produce fish that have high mercury concentrations. On the other hand, the
bioaccumulation factor (BAF) varies a great deal from lake to lake and is difficult to predict
because background chemistry affects the BAF to a great degree. Some of this variability is
doubtless from differences in the efficiency of methylation of mercury in a given lake, because
only methyl mercury bioaccumulates in the food chain.
Even if water quality managers reduced mercury to zero in point discharges, fish may still
exceed the FDA action level of 1.0 ppm. Nonpoint sources of mercury have been shown to
be the origin of mercury contamination of a broad range of lakes, ranging from small seepage
lakes in Wisconsin to Lake Superior. Although geological sources may be significant in a few
parts of the world, most of the nonpoint mercury is deposited from the atmosphere to soils,
where a portion (about 20 percent) is transported to lakes and streams. Once in water, a
small but variable proportion (about ten percent) is methylated and can be bioaccumulated.
Some of the mercury evades back to the atmosphere, but the majority falls to the bottom of
the lake. It is likely that little of the sedimentary mercury is available to the food chain. The
connection between air emissions and fish mercury is highly complicated and subject to
mechanisms that would require considerable research for a full understanding. For instance,
it is unclear how mercury vapor is removed from the atmosphere. Mercury vapor needs to
be converted to a water soluble form to be washed out, but dry deposition may be a
significant mechanism. Some mercury is emitted in a water-soluble form, so that deposition
around some sources may be enhanced.
It would be possible to research the mercury path between air and fish for years and not be
able to construct a useful mechanistic model. We do know, however, that most of the
mercury in the atmosphere is human-generated, and that reducing emissions will reduce fish
contamination. Air emissions are split between energy production and product
manufacturing/disposal. Water managers need to work with air and solid waste managers in
their pursuit of mercury control. Point source control, while necessary, is not sufficient to
reduce mercury to acceptable levels.
1-17
-------
Session I
The EPA should provide leadership for integrated approaches to airborne pollutants such as
mercury. Communication among EPA's water, air, and solid waste offices should be fostered.
A mechanism to coordinate guidance and rules should be established.
1-18
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Session I
Water Quality and Standards for the 21st Century
CRITERIA DEVELOPMENT PAST, PRESENT, AND FUTURE
Robert T. Angelo, Ph.D.
Chief, Science and Standard Section
Kansas Department of Health and Environment
Topeka, KS
SUMMARY
Speaking on role of specific water quality criteria for pollutants
Kansas is 49th in overall water quality conditions in US
fewer than 10% of waters support all designated uses
biggest problem is non-point source pollution
TSS, TDS, sediments, fecal coliform, agricultural chemicals
90% of surface area has been converted to farm land
2.5 cows and swine per person
some problems related to historical mining of coal and zinc and lead ores
Water related impacts
Have numerous dams resulting in habitat loss
Have lost a number of aquatic species - several mussels and fish
Widespread dewatering of streams and springs in western Kansas
Ground water depletion
Loss of riparian and wetlands
About 95% of streams in Kansas are not in full compliance with WQS
Kansas making major investment in anti-degradation
designation of 35 streams and 12 wetlands as outstanding Natural Resource waters
Economic impact is felt most by wastewater treatment facilities although make up small
percentage of problem
shallow water tables have led to contamination from livestock opertions, fertilizer
application, ammonia, etc.
show increase in nitrates in drinking water wells
Standards recently revised - included in National Toxics Rules
Over 200 parameters with numeric criteria
Included WET provisions
Narrative provision for protection of wildlife
Criteria don't address multi-media
1-19
-------
Session I
Don't address habitat impacts
Chemical-specific Standards are:
Resource intensive
Assumptions are too simplistic (mixing zones, etc.)
Do not address synergistic effects
Do not adequately address non-point sources
Media to media transfer not considered
State lines are not considered
However, ease of application
familiarity with process, easy to understand
can be easily and directly measured
Do numeric criteria still play a part in WQS?
Yes, states have invested too much time and money.
Kansas will invest in chemical specific as backbone of program and will supplement with
BMPs, WET testing, and pollution prevention.
Need greater research by EPA in areas of BMP, mutagens, teratogens, pollution prevention,
etc.
Recognize that states will not be able to implement these new initiatives overnight but they
will keep trying.
1-20
-------
Session 1
Water Quality and Standards for the 21st Century
CRITERIA DEVELOPMENT PAST, PRESENT, AND FUTURE
Philip G. Watanabe, Ph.D.
Director
Health and Environmental Sciences
Dow Chemical Company
Midland, Ml
SUMMARY
Would like to contribute to conference on scientific issues by adding'discussion of sociological
issues
We are all in the same boat
desire clean water
recognize it is not acceptable to release persistent chemicals to environment
industry has changed its modes of operation
all stackholders should be involved
Decision factors - how/what to do to protect human and environmental health while
maintaining standards of living and protection of future generations
scientific factors - facts, uncertainty -
caution not to oversell value of science
reach stages where we can make sound decisions
sociological factors - values, economics
decisions are driven as much by sociological factors as they are by scientific
information. (Previous conference discussion on what causes tort litigation is more
sociological - perception of effect rather than scientific established cause and
effect)
technology factors - pollution prevention hierarchy
transfer of scientific information to engineering solutions
Complex issues require integrated solutions - base decisions on
rigorous science - evaluation of health and environment
better exposure data/global fate and distribution
environmental equity
economics
evaluation of alternatives
Current Activities
Committee on Social Environment
Life Cycle analysis
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Session I
fate/distribution
impact analysis
Evaluation of various Decision Models for selecting target chemicals
George Washington University - Dr. Furan
University of Tennessee
Needs
Good economic analysis
jobless people aren't healthy people
Global approach
Incentives to plan best for long range
Professionals to solve technological problems
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Session I
Water Quality and Standards for the 21st Century
CRITERIA DEVELOPMENT PAST, PRESENT, AND FUTURE
Tim A. Eder
National Wildlife Federation
Ann Arbor, Ml
SUMMARY
Manager of Water Quality Program
worked on CWA last four years
Great Lakes Initiative five years
currently working on Virtual Elimination Task Force to eliminate persistent
chemicals from the Great Lakes Basin
Background on GLI
Ecosystem based approach to protecting a unique system
EPA should consider similar approach for other areas
Program will be a set of regulations with water quality criteria to protect human health,
aquatic and wildlife
new anti-degradation proceeds
National Wildlife Federation (NWF) has been involved since start of program.
Great Lakes Initiative (GLI) was developed by committee (including citizen, industry,
and government groups)
Characteristics of Great Lakes
Great Lakes don't flush out. Only about 1% volume is discharged, therefore,
pollutants bioaccumulate.
Politically unique. For example, US made commitment to eliminate discharges of
persistent chemicals to Canada.
Recommendations regarding current program:
NWF is concerned about effects of toxic chemicals on endocrine system
NWF recommends EPA ban/phaseout chemicals which bioaccumulate
Put a screening assay in place
Agree that we must take action prior to having all the answers, we'll never have all the
answers
Environmental Equity
assumptions of fish consumption are unacceptable. Executive order sites EPA directive
to update this.
Example: creating standards assuming people only eat fish one meal every six
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Session I
weeks (limited amount)
Everyone should be able to eat fish as much as they want (cultural, religious, etc.
reasons)
Many communities in Great Lakes depend on fish
EPA needs better methods and must use a multi-media approach, should address all sources
(example: air sources), single media focus will not be enough
EPA should reassess risk program.
Several chemical control strategies are based on safe levels
shouldn't abandon criteria approach, but should ban some uses of certain chemicals
Example: Chlorine - studied uses of chlorine of 4 industries and called to eliminate
several uses
New approach: work with industries to study particular pollutant and potentially eliminate
certain uses.
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Session I
Water Quality and Standards for the 21st Century
SESSION 1: QUESTIONS AND ANSWERS
Q: Given new EPA policy of watershed protection and innovative criteria, how will EPA
deal with state and local agencies that try to implement creative approaches when
they don't have flexibility to ignore criteria? Will we get sued if we do not meet these
criteria?
A: EPA needs to work together with the states and localities to find out what is important
to each entity and to identify alternatives and negotiate implementation strategies and
changes to program.
Q: EPA wants to emphasize "Greatest Environmental Benefit." How is this defined?
A: EPA needs to work with all affected parties to determine which advances are the most
advantageous for environmental benefit.
Q: For Ed Swain: Perhaps water column measurement is not the best for measuring
effects of mercury.
Official detection limit for mercury is 200 nanograms/l
Criteria is 12 nanograms/l
Ambient cone, are 1 nanograms/l
Consultants have developed methods to .5
EPA has not followed up and approved this method.
A: Until recently could not measure to the water quality criteria. Therefore EPA should
revise the methods required to meet mercury limits. There are available methods to
measure small quantities. Measuring the concentration of mercury in the water column
may not show the real problem and impacts. Methyl mercury is the form which has
the impacts because it is rapidly taken up in tissues. Therefore the water quality
criteria will not protect the environment. You must use both measurement of the
water column and measurement of mercury in fish tissue to determine the whole
problem.
C: To Morris: Three legged approach
1. Water chemistry leg should add to aquatic life and health including:
sediment „
nutrient ,
wildlife
2. Develop ambient monitoring programs
strides in biological criteria
have rivers and streams; need lakes, wetlands, estuaries
also need habitat criteria
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Session I
3. Toxicity testing
now have Wetlands
need site specific alternatives or adjustments like water effects
to use in addition to WET
Q: (Teresa, API) Common Sense Initiative, how does future direction affect GLI?
A: GLI is EPA's state of the art and may be the best that we can do at this time.
However because of time constraints, there is a lot more EPA would like to do and will
do in the future.
Q: (Dick Schover, Dupont) Three legged analysis is another example of independent
applicability. EPA has chemical criteria, WET criteria, biological criteria. If any of these
sources shows a problem we must do something about it. How will this policy fit in
with the future?
A: We are currently looking at the policy. There are areas where if a state has enough
info to make decisions with one or two pieces of information, EPA will allow the
decisions to be made. EPA is looking at watershed-based permitting
EPA is reviewing policy; has circulated paper for comment.
Q: What approach is EPA taking to involve industry in water quality regulation
development?
A: EPA has opened up workgroups to industry members. There is an upcoming meeting
for Aquatic Life Guidelines at EPA Lab in Duluth. On human health there was a
national meeting held recently.
Q: Does EPA plan to monitor actual impacts to determine if additional measures are
needed?
A: There is an ad hoc session on monitoring tomorrow. A work group is currently trying
to standardize questions asked under 305(B) program to allow for consistency.
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Session I
Water Quality and Standards for the 21st Century
SESSION 1: Questions from cards (Not anwered at the Conference)
Q. What is EPA's position and/or recommendation on using a low stream flow value of
1Q10 versus 7Q10 in the modelling for chronic and acute toxicity criteria?
A. EPA continues to recommend 1Q10 for acute and 7Q10 for chronic criteria, as these
flows will generally provide a very high degree of protection. The recommended
frequency is under review as part of the revision to the Aquatic Life Guidelines. EPA
may approve a State's use of less stringent design flows if the State provides a sound
scientific rationale.
Q. Session I advocated flexibility and innovation in addressing pollution control and water
quality criteria. Yet state water quality standards and implementation procedures are
judged against other state programs, often without regard to the individual state's
ability to carry out the innovative approaches and protect water quality. Is this
comparison of programs going to stop? How are you (EPA) going to address this?
A. See Ed. Note
Q. When performing risk assessments in the face of uncertainty, there is a tendency to
specify criteria in the most conservative manner. Significant resources may be spent
by dischargers to meet resulting standards. When uncertainty is reduced and if criteria
are changed to reflect this change, dischargers are still backed into meeting the initial
criteria due to anti-backsliding and anti-degradation concerns. Wouldn't it be more
reasonable to use a less conservative starting point and move down if necessary?
A. See Ed. Note
Q. Virtually every speaker said non-point sources are more significant than the already-
compliant point sources. However, every strategy or plan seems to consider point
sources as the cure or control point, i.e., more stringent end-of-pipe WQS. What
innovations does EPA envision to address this discrepancy?
A. EPA is moving on two fronts to address NPS problems: (1) the implementation of NPS
controls, and (2) the developmnt of better NPS science. The following examples
illustate efforts in these two areas.
Implementing NPS Controls: EPA awards grants to States, Territories, and Tribes
under Section 319 of the Clean Water Act (CWA) for the purpose of implementing
programs that reduce NPS impacts to surface and ground waters that are impaired or
threatened by nonpoint sources. Section 319 funding was $80 million in FY 1994,
and is increasing to $100 million in FY 1995. EPA is also working with NOAA to
implement the Coastal Nonpoint Pollution Control Program under Section 6217 of the
Coastal Zone Management Act Reauthorization Amendments of 1990 (CZARA).
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Session I
CZARA requires that 29 coastal States and Teritories develop and implement
"management measures" to control nonpoint sources of pollution to coastal waters.
States and territories that fail to implement programs under CZARA are subject to loss
of funds under both Section 319 of the CWA and Section 306 of the Coastal Zone
Management Act of 1972.
Developing BetterNPS Science: Excess nutrients are a major problem in U.S. waters.
The failure to implement an effective nutrient control program stems in part from a lack
of scientifically defensible endpoints for ambint waters, and the inability to translate
endpoints, where available, into a comprehensive nutrient control strategy. EPA is in
the preliminary stages of developing a national nutrient control strategy. The oveall
goal is to identify and implement a focused effort to address the nutrient problems in
U.S. waters.
Q. How does a water quality based approach replace numerical limits on existing NPDES
Permits? Indicator parameters. At what point will The Clean Water Act interface with
the drinking water act in a water quality based approach?
A. As part of the Water Quality-Based Approach numerical effluent limits are calculated
to meet water quality standards. EPA doees not anticipate the removal or replacement
of the requirements of numerical NPDES effluent limits at this time. An obvious area
where the Clean Water Act and Safe Drinking Water Act will interface is in the
protection of source waters for drinking.
Q. Why develop new methods to evaluate risks, when you still don't know whether
current methods are any good?
A. The methods under development by EPA (sediment criteria, wildlife criteria,
bioaccumulation methods, etc.) are areas where EPA has not focused atttention in the
past. EPEA is also reevaluating existing methods, piolicies and protocols and revising
these methods as needed (e.g., aquatic life tuidelines, human health guidelines, and
metals criteria policies are some being reevaluated.)
Q. What does EPA mean by "innovative application of criteria?" Please define and give
some concrete examples.
A. EPA encourages the use of criteria in a non-regulatory context where appropriate. A
concrete example is the Chesapeake Bay Program Office who has developed dissolved
oxygen goals and is using these as a spearhead in the reduction of nutrient loadings
into the Chesapeake Bay. Criteria may alo be used as assessment tools in the problem
formulation phase of an ecological risk assessment.
Q. Does EPA view the Great Lakes Initiative Tier II procedure as a prototype of simplified
methodology development requiring less data? How should the greater uncertainty and
inaccuracy of these values be recognized in implementation (i.e., NPDES permitting)?
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Session I
Water Quality and Standards for the 21st Century
A. The Great Lakes Initiative (GLI) Tier II methodology was developed for the express
purpose of deriving criteria for regulatory purposes where the data do not exist to
derive a Tier I criteria. EPA believes at this time the Tier II methodology is a good
prototype. However, EPA would have some reservations of utilizing this methodology
exclusively (i.e., in place of the Tier I methodology). The final Great Lakes Water
Quality Guidance should anwer the question of how to implement values based on
limited data, such as the GLI Tier II values.
Q. How soon can we expect to see new criteria as ranges? Will there be a methodology
that can be retrospectively to existing criteria to make them more flexible? What does
EPA headquarters plan to do to assure that the EPA regions will allow states or local
governments to be innovative and flexible to discourage regional cookie cutter
approach?
A. If EPA decides to produce national criteria recommendations as ranges it is unlikely to
be released prior to "1996. EPA is considering deriving a methodology that can be
retrospectively applied to existing criteria.
Q. Presently EPA seems to have limited staffing and resources to direct to criteria
development and implementation. The agenda for the future is impressive, but will
EPA be given the resources to carry it out? Do you have completion date goals for any
of these?
A. This conference is to solicit comment on this agenda. Overall resources for EPA,
States, Tribes, and the regulated community are shrinking. This makes it imperative
that EPA and the other parties learn how to leverage the resources available to acquire
the necessities of ecosystem protection.
C. I would like to see environmental basis for EPA second guessing state programs and
decisions, (from John Hensel, Minnesota Pollution Control Agency)
[Ed. Note: The purpose of these proceedings is to provide a written compendium of the
presentations and discussions as soon after the conference as possible. It is being published
even though answers to some of the questions are not available. Persons interested in the
answer to this question are encouraged to continue discussions with the appropriate sources.]
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Session 2
Addressing Ecological
Integrity:
Moving Beyond Chemical Toxicity
TT
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Session 2
Water Quality Criteria and Standards for the 21st Century
ADDRESSING ECOLOGICAL INTEGRITY: MOVING BEYOND CHEMICAL
TOXICITY
Susan Jackson
Environmental Scientist
Health and Ecological Criteria Division
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
Session Moderator
Abstract: This session covers approaches for managing environmental stressors that are
adversely affecting water quality and aquatic ecosystems but are not part of EPA's regulatory
program. These stressors include habitat degradation, nutrient enrichment, and hydrologic
modification. At this session, participants are presented information on how to estimate the
cumulative impacts of all stressors in a watershed, available tools for addressing them, and
ways to build close working partnerships with other federal, state and tribal agencies in
developing and implementing water quality and resource management. Technical, legal, and
implementation issues will be a part of the discussions.
SUMMARY
Conference purpose:
- focus of science needed to achieve ecosystem protection
- seeking your input
Session 2 focus:
- Scientific tools to address aquatic problem such as nutrient over enrichment,
habitat degradation, sedimentation, alteration of water quality and flow
- Discuss how these tools differ from traditional water quality criteria
- Organized to showcase how criteria are developed to address problems highlighted
above
Organization of session:
1 st part: nutrient/over enrichment, modification, sediments
(R. Batiuk, C. Yoder, G. Harvey, T. Fontaine)
2nd part: hydrologic modification habitat loss
(M. Dodson, J. Johns, P. Wright, E. Mead, D. Braun)
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Session 2
NUTRIENT ENRICHMENT, HABITAT, AND RESOURCES RESTORATION
GOAL SETTING IN THE CHESAPEAKE BAY PROGRAM
Richard Batiuk
Toxics Coordinator
Chesapeake Bay Program Office
U.S. Environmental Protection Agency
Region III
Annapolis, MD
Abstract: Building from the 1987 Chesapeake Bay Agreement's goal for the "restoration and
protection of the Bay's living resources, their habitats, the ecological relationships", there has
been a consensus-based evolution within the Chesapeake Bay Program towards developing
and adopting increasingly quantitative habitat and resource restoration goals. This
presentation will highlight five sets of goals, methods used in their development,
implementation within habitat restoration and pollution abatement programs, and resultant
recommendations to the national program.
Dissolved oxygen restoration goals
Nutrient and light attenuation habitat requirements
Submerged aquatic vegetation restoration goals
Benthic community restoration goals
Living resource restoration goals under development.
These goal setting efforts will be presented in the context of a larger effort to institutionalize
links between resource management, habitat restoration and pollution reduction/prevention.
SUMMARY
Chesapeake Bay Program includes State/Federal, Academic and local agencies, (e.g.,
Chesapeake Bay Foundation it is a collective consortium.) States include PA, MD, DC, and
VA.
Chesapeake Bay Program goals:
Find issues that we can effect and then improve these
Ask public what does a healthy watershed mean to you?
Key in Chesapeake Bay is identify what we are there for
Resource, example: Bay grasses
Outcome, example: Sustained Harvests
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Session 2
Water Quality Criteria and Standards for the 21st Century
Idea is to link habitat to resources.
Conceptual model
compiled info on bay grasses
knew in what areas grasses were effected by nutrients etc.
Predicted effects of varying factors.
started with studying light as limiting factor
Numerical requirements by ranges:
lists assumptions and says within a particular range grasses would grow.
this allows us to look at nutriential requirements in Bay
allows to put together a habitat requirement map and show where grasses may be
returned if certain changes in nutrient levels, etc. are achieved.
Dissolved Oxygen Restoration Goals
Find existing data showing dissolved oxygen levels needed for certain species.
This showed us what we need to strive to achieve and helped develop a basin wide
restoration goal.
spawning river habitat
upper water column
lower water column
sediment
5 mg/l at all times
5 mg/l monthly average
1-3 mg/l
1 mg/l
Benthic Community Restoration goals
Study inspected benthic community in non-degraded habitat based on seven different
habitat classes by salinity, sediment type, different matrixes
This allows us to compare Chesapeake Bay benthic community conditions to expected
communities in non-degraded systems. This will help identify potential
problems and problem areas.
Recommendations for EPA to consider:
Nutrient Criteria:
• Set threshold requirements for body of science supporting nutrient
criteria
• Establish national policy linkages
Support technical transfers necessary for implementation modeling
Estuarine/Marine Dissolved Oxygen criteria:
• Support/promote water body based criterion development
• Address implementation within criterion development
• Recognize need for estuarine criteria (there are several sensitive
estuarine species)
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Session 2
Biological criteria:
• Connect habitat degradation to watershed based activities, ex. harvest,
watershed
Summary
* Hold ourselves accountable to the public by setting meaningful goals
that can be measured
• Link problems to sources the people can understand.
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Session 2
Water Quality Criteria and Standards for the 21st Century
ADDRESSING NUTRIENT OVERENRICHMENT AND HABITAT
DEGRADATION
Chris O. Yoder
Manager
Ecological Assessment Section
Division of Surface Water
Ohio Environmental Protection Agency
Columbus, OH
Abstract: Current methods to develop biological criteria and habitat assessment, with
emphasis on addressing impacts of nutrient enrichment and habitat degradation on aquatic
communities.
Habitat assessment as an integral component of biological assessments.
Recommendations to EPA National Program for- developing future/needed methods for
biological and habitat assessment.
SUMMARY
Five factors determine integrity of water resource:
chemical variables
flow restrictions
Biological criteria are narrative or numerical expressions based on reference condition of least
impacted aquatic community inhabiting waters of a region.
can't establish national numbers,
can create framework to use in different regions
In Ohio biocriteria define fish and macrovertebrates community structure and
they vary with ecoregions across the State.
Monitoring design is critical first step
Aquatic life impairment causes:
organic/DO
siltation
metals
flows
nitrates
habitat mod
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Session 2
Habitat Assessment is conducted by applying Qualitative Habitat Evaluation Indices (QHEI)
substrate
instream cover
channel quality
riparian/bank stability
pool/riffle river
Area of degradation value based on - how far from the biological criteria goal is the water
body degraded.
Plot IBI versus ratio of modified water attributes/warm water attributes
Headwater sewage problem - Phosphorus in headwater streams
• higher phosphorus in the water column, lower the habitat quality
• in healthy headwaters the phosphorus is in the plants and animals
• in unhealthy it is in the water column causing habitat degradation
Consequences of using stream beds to run sewer interceptors
created larger problem
Stream miles impaired due to combination of point source and nonpoint source pollution
• at present, reducing point source faster than NPS
• to achieve use restoration must address NPS
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Session 2
Water Quality Criteria and Standards for the 21st Century
WATER QUALITY CRITERIA FOR UNCONTAMINATED SEDIMENTS
Geoffrey W. Harvey
Senior Surface Water Analyst
Division of Environmental Quality
Northern Idaho Regional Office
Idaho Department of Health and Welfare
Coeur d'Alene, ID
Abstract- Key Points:
• In many western states uncontaminated sediment is the most prevalent
contaminant of water.
• Uncontaminated sediment occurs as a natural product of erosion, but^erosion
rates and sedimentation are accelerated by nonpoint source activities making
sediment a contaminant.
• Any criteria or standards promulgated to protect beneficial uses from
accelerated sedimentation must consider sediment impacts on the water
column and the stream bed load to adequately protect the beneficial uses,
especially freshwater biota habitat as related to these uses.
• Criteria and standards must be chosen which are directly related to the
protection of the beneficial use's habitat.
• Since sediment is primarily generated from nonpoint source activities (irrigation,
logging, grazing etc.) sediment criteria are often used to assess the
effectiveness of best management practices.
Impacts of Uncontaminated Sediment on Freshwater Biota Beneficial Uses
• Interference with sight feeding fish species (e.g., salmonids).
• Loss of juvenile and over-wintering habitat; cobble interstitial space.
• Loss of adult holding habitat; pool filling.
• Loss of spawning habitat: oxygen transport interference and sediment
retardation of fry escape from the redd.
EXAMPLE: Water Column Based Sediment Criteria
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Session 2
Salmonid Sight Feeding Criterion
In surface waters supporting or capable of supporting salmonid fisheries, turbidity, as the
result of nonpoint source activities, shall not exceed background turbidity measured at
comparable discharge by 50 NTU instantaneously or 25 NTU for 10 days.
EXAMPLE: Stream Bed Based Criteria
Salmonid Holding Habitat Criterion
Residual pool volume of a representative stream reach may not be significantly (95%
confidence interval) altered by bedload sedimentation.
Salmonid Rearing Habitat Criterion
Natural baseline interstitial space index of the cobble and boulder substrate of a representative
stream reach shall not exhibit a statistically demonstratable decrease at the ninety-five percent
(95%) confidence interval. Impacts of sedimentation on the interstitial space habitats
important to salmonid rearing and refuge will be assessed by measurement of the cobble and
boulder interstitial space index. Baseline interstitial space index will be determined by a
quantitative technique in stream reaches with similar geomorphology and stream power which
are unaffected by human induced (i.e., nonpoint source) sedimentation. An interstitial space
index value will consist of a mean at the ninety-five percent (95%) precision level of the 1:
statistic.
Salmonid Spawning Criterion
Nonpoint source activities shall not cause intergravel dissolved oxygen in spawning gravels
to decline, below a weekly average of 6 milligrams per liter.
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Session 2
Water Quality Criteria and Standards for the 21st Century
ADDRESSING NUTRIENT OVERENRICHMENT AND HABITAT
DEGRADATION
Tom Fontaine
South Florida Water Management District
West Palm Beach, FL
SUMMARY
Integrated system approach to Everglades restoration
Facing competing demands for water - First: define hydrologic needs of ecosystem,
then agriculture, urban uses get what is left over
Phosphorus is key problem (mostly from agricultural runoff).
Florida has developed 50 stormwater treatment areas
Consisting of 40,000 acres of wetlands used to intercept agricultural runoff before it
reaches the Everglades.
System is set up to reduce phosphorous to 50 parts per billion
Florida standard is "no imbalance."
What level of nutrient causes switch from saw grass to cattails?
• Cattails tend to grow at higher nutrients this is not desired because
cattails take over the natural vegetation when phosphorus levels
increase.
• State experiments with tubs of grasses to get defensible statistically
significant data.
Florida is using natural systems model to predict what impacts moving water from one area
to another has on the vegetation.
Use this to set restoration goals
Hydrology under managed and natural
Set hydroperiod restoration goals for Everglades
Landscape model
Measures only vegetation response to nutrients.
It will be several years before the model is complete.
Natural park - wildlife data will be added to the model.
Recommendations to EPA:
• Adaptive approaches
• Don't wait for perfect information to get started.
^ • Need specific criteria for wetlands.
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Session 2
SESSION II: QUESTIONS AND ANSWERS
Q: Do you see a role for EPA on a national level in attacking clean sediment problem? (Bob
April)
A: Clean sediment criteria will be a more regional issue. What Idaho has done so far is
applicable to other mountain neighboring states, but criteria needs to be homegrown
criteria. At national level role should be in communication between difference areas,
information transfer. (Harvey)
A: Issues Idaho are addressing are very applicable to our streams, the clean sediment
information from Idaho are appropriate to warm water streams. Needs to be linked to
biological criteria to measure the end product. (Yoder)
A: Habitat criteria must be further explored. Large part of problem is cows walking
through stream which are not controlled by NPDES permit. Part of the continuum to
protect the streams.(Batiuk)
A: In Florida we have problems with humic acids. This is a bioavailable issue (Fontaine)
Q: How do you apply criteria in permits and enforce them? How do you apply criteria to
nonpoint sources and determine they are being met? (Mary Jo Garreis)
A: For the most part we do not. The farmer or logger is required by law to implement
BMPs. If farmer/logger is performing the BMP, the law has been met. We use in-
stream criteria to determine if BMP is working and if its not, the State must develop
new BMPs. Lack of funding is a serious problem. (Harvey)
Q: Are loggers required to have permits?
A: Yes, loggers have a notice (a type of permit) that requires implementation of BMPs, but
are not required to do monitoring to prove BMP works.
Q: If you are basing criteria on reference of natural condition, how do you decide what
reference is? Is the decision hard? How do you draw line between what meets criteria
or not? (Jerome G., Tetratech, Corp.)
A: For SAV, In Chesapeake Bay, we used historical data such as the amount of grasses
in the past and studies that indicated in what conditions grasses should grow. We
looked at 20 years of aerial survey records. We then looked at the grasses in the
Chesapeake Bay in areas that are not impacted. For benthic ecosystem, there were
no pristine areas, but identified low impact systems. For dissolved oxygen, looked at
gradation in stream achievable and what aquatic life needed. (Batiuk)
A: In the Everglades, we used cores (dating cores) to determine historical flow and past
water conditions to set baseline. We also looked at plant materials to get an idea of
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eSSIOn Water Quality Criteria and Standards for the 21st Century
what system use to be, to describe prior conditions. (Fontaine)
A:
A:
Q:
A:
Q:
A:
There are steps in setting numeric criteria, as described in proceedings on the 1991
biocriteria symposium (Yoder) (EPA-440/5-91-005).
Idaho is in the position of having low impact areas that can be used for references.
(Geoffrey)
What kind of wetlands do you have, how do you collect and dispose of phosphorous?
Cattail marshes are used to collect phosphorous; nothing is being done to remove it,
it stays in the cattails and sediments in the marshes. (Fontaine)
What changes are necessary in the future to further reduce phosphorous, further
reduce runoff?
Farms implementing BMPs, farm BMPs have achieved 40% reduction in total runoff,
other options are water treatment plants. (Fontaine)
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Session 2
Water Quality Criteria and Standards for the 21st Century
ADDRESSING HYDROLOGIC MODIFICATION AND HABITAT LOSS
WATER QUALITY IN THE ARID WEST: IS THERE A ROLE FOR EPA IN
ADVANCING SOLUTIONS TO THE CONFLICTS BETWEEN INSTREAM
FLOW AND HYDROLOGIC MODIFICATION?
Max H. Dodson
Director
Water Management Division
U.S. EPA, Region 8
Denver, CO
Abstract: The objective of the Clean Water Act establishes a broad ecological goal aimed at
restoration and maintenance of the chemical, physical and biological integrity of the Nation's
waters. However, the substantive part of the Act, implementing that objective, is principally
constructed to address the discharge of pollutants, and it is this control of pollutant
discharges which has appropriately occupied EPA's attention over the last twenty years.
There is now, however, a growing awareness within the Agency of the need to address
impacts to the water resource as a whole and refocus attention on the Act's ecological
integrity objective. This new focus is evident in the Agency's growing interest in landscape
level approaches to water resource protection such as watershed protection and ecosystem
management. Clearly, the presence of water will be a key component in satisfying an
objective aimed at maintaining the ecological integrity of aquatic ecosystems. As a result, the
Agency's interest in watershed protection and ecosystem management, necessarily, will force
a somewhat more active Agency role in water quantity issues. In the arid west, there is a
somewhat more active Agency role in water quantity issues. In the arid west, there is a
continuing conflict between maintenance of instream flows for the protection of aquatic
ecosystems and hydrologic modifications which dewater streams to meet offstream demands.
This conflict is compounded by western water laws which view water as a property right.
The right to allocate water is acknowledged in the Clean Water Act in Section 101(g);
however, the courts and EPA have interpreted this provision as requiring an accommodation
of quantity and quality demands. Furthermore, the recent U.S. Supreme Court ruling, in a
case addressing instream flow requirements in the State of Washington, appears to strengthen
the standing of the ecological integrity objective of the Act. Is there a role, then, for EPA in
negotiating an accommodation between instream flows needed to meet the Act's ecological
objective and hydrologic modifications designed to satisfy legitimate offstream demands also
recognized by the Act? Three case studies in Region VIII will be used to illustrate the conflicts
and a potential role for EPA in negotiating accommodation.
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Session 2
SUMMARY
Water Quality in West is very controversial
need accommodation of both quantity and quality demands
working toward resolution of water quality conflicts will require
- sound technical tools to identify threshold flow regimes needed to meet
CWA ecological integrity objective.
— implementation process to accommodate other competing uses of water
the very presence of water shows need for ecological system protection
aquatic organisms require water 365 days a year
issues compounded by Western Water Law
— water is viewed as a "property" right.
- the highest use must be maintained or it can be taken from you - this
complicates the conflict issue
Two Supreme Court statements which strengthen the EPA's and States' position:
(1) There is a link between water quality and quantity.
(2) There is a recognition in the CWA that the diversion of water (diminishment of
flow) can be considered a pollutant.
Kingsley Dam - example of relationship between flow and temperature
— contentions issue
— impacts Big Bend of Plat River
Key Question: how much water can be used for agriculture and other uses until it
impacts flow and thus the temperature and therefore the critical habitats for the
wildlife.
— Required minimum flow on 3 communities in county with dams
Key to solving conflicts in West is to reach a decision that will not drop quantity below safe
annual yield - the minimum amount of water that can be expected even in a drought year.
Summary - We are all consumers of water
historically focus has been on our needs for water (drinking, recreation, fishing)
Often those uses are in conflict with each other; ex., in August drinkers want high
volume, fishers want low flow
Bottom line is ecological integrity vs. our needs for the water
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Session 2
Water Quality Criteria and Standards for the 21st Century
ESTABLISHING STANDARDS FOR CALIFORNIA'S SAN FRANCISCO
BAY/SACRAMENTO - SAN JOAQUIN DELTA ESTUARY
Jerry Johns
Assistant Division Chief
Division of Water flights
California State Water Resources Control Board
Sacramento, CA
Abstract: California's San Francisco Bay/Sacramento-San Joaquin Delta Estuary (Bay/Delta
Estuary) is not only the largest estuary on the west coast of the United States but is also the
critical water supply link between the water surplus areas in the northern part of California
and the water deficient areas in the southern and coastal regions of the State. The factors
influencing the biological resources in the Bay/Delta Estuary will be discussed. Also, State
and Federal approaches to stop the current decline of the biological resources and improve
estuarine habitat will be presented.
One factor affecting the biological resources in the Bay/Delta Estuary is the reduction in flow
out of the freshwater Delta portion of the estuary into the saline bay portion of the estuary.
Numerous studies show a positive relationship between freshwater flow out of the Delta and
the populations of various trophic levels of organisms that live in or depend on the estuary for
a portion of their life cycle. As is typical for estuaries, flows and salinities are closely
correlated. Decreases in flows result in increases in salinity. The relationships between flows
and biological production have been reformulated to show similar relationships between
salinity and tropic response. The pros and cons of setting standards on either flows or salinity
will be discussed from a scientific, regulatory and political viewpoint.
Another large factor affecting the biological resources in the Delta portion of the Bay Delta
Estuary is water diversions from the Delta. These diversions occur to satisfy, both the
550,000 acres of agricultural land within the Delta and the approximately six million acre-feet
of water exported from the Estuary for use in areas to the south and west. Controls on the
timing and amount of these exports have been placed on the operators of these export
facilities as requirements under the Endangered Species Act to protect winter run salmon and
Delta Smelt. Additional controls are likely needed to protect other species. Factors other than
flow (salinity) and diversions have also affected the biological resources of the Bay Delta
Estuary, but these two factors are the most controllable factors which have the largest effect
on these resources.
All of the standards for Bay Delta Estuary affect-the available water supply for much of the
State's agricultural land and most of it's people. The establishment and enforcement of these
standards must strike a reasonable balance between the legitimate needs of both in stream
and out of stream uses of water. They must also be sensitive to the State's long guarded
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desire to have control over water allocation decisions and the Clean Water Act's structural
inability to allow the kind of balancing needed when two beneficial uses of water compete for
the same resources.
SUMMARY
Water quality standards - Need to look at effect response curve
For developing flow criteria, laboratory data is useless,
must be developed in the field
Basic problems in California
80% of water use is in Southern 2/3 of state
70% of precipitation falls in North 1/3
San Francisco Bay-Delta Watershed
2/3 of water consumed
700 reservoirs
1/2 water rights in watershed
In California have looked at factors affecting use
As flow increases, abundance increases proportionately
No abundance flows - fish could use it all
none to allocate
Factors affecting San Joaquin Watershed
EPA has proposed salinity standards
Pumps in watershed can reverse flows
Diverts fish out of the system trying to exit to ocean -
fish are collected and trucked to estuary
Inflows, screening factors - fish screening at pumping stations
Water qualities set by EPA are deficient for use in flow standards
because set up for polluters to protect use from industrial discharges
If have competing uses, can't protect most stringent uses
Existing regulations say protect uses, but can't protect both, must balance
CWA is not an appropriate legal mechanism - cannot allow for balance
At issue:
deciding flow between two beneficial uses that are competing - flow vs
drinking water
Need EPA to help with development of tools to develop the criteria
States should develop and implement those standards
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Water Quality Criteria and Standards for the 21st Century
ADDRESSING HYDROLOGIC MODIFICATION AND HABITAT LOSS
Patrick Wright
Chief, Bay/Delta Section
U.S. Environmental Protection Agency
Region 9
San Francisco, CA
Abstract: Collaboration with other Federal agencies to develop and apply methods to address
the impacts of water withdrawal on aquatic communities, development and application of
methods within context of watershed approach to comprehensive ecosystem protection.
SUMMARY
EPA's role should be to work closely with state, however, if water uses are not being met
EPA will act more formally.
1987 - EPA found state standards inadequate.
December 1993 - EPA proposed federal criteria for the Bay Delta
EPA is now working with the state to develop standards the state can adopt.
EPA is open to options other than just salinity criteria, which is being developed.
Salinity criteria is to protect mixing zone. EPA used historical information in trying to
model what the conditions of the bay should be.
Why use salinity standards?
Scientific information
Legal reasons
Management reasons
Fish screening (salmon)
Key is to keep fish in main channel for them to avoid getting stuck in the pumps.
EPA left this to state and is focusing on restoration goal.
Settled on goal and are allowing state to find methods to meet this goal
EPA will focus on outcomes instead of specific criteria, thus giving the state
flexibility in how to meet goals.
Flow standards serve as measures to provide feedback on management plans
Endangered Species Act
Important lessons have arisen from Bay
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CWA provides flexibility to act before the ESA acts
CWA may be used to help promote habitat
There is a need to include provisions in the reauthorization of the Clean water Act to allow
EPA to make policy on flow matters so EPA can work with states to solve water management
issues. This will assure States that EPA will work with them in solving
these issues.
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Water Quality Criteria and Standards for the 21st Century
ADDRESSING HYDROLOGIC MODIFICATION AND HABITAT LOSS
TOOLS TO ASSESS THE IMPACTS OF HYDROLOGIC MODIFICATION ON
AQUATIC COMMUNITIES
Estyn R. Mead
Fish and Wildlife Biologist
Branch of Federal Activities
Division of Habitat Conservation
U.S. Fish and Wildlife Service
Arlington, VA
Abstract.-The Fish and Wildlife Service has used a variety of methods to assess the effects
of stream flow regulation on aquatic biota and to provide instream flow recommendations.
Instream flow analysts have divided these methodologies into two categories, standard-setting
and incremental, depending on the objectives and complexity of the decision process involved.
Standard-setting methodologies refer to those measurements and interpretative techniques
designed to generate a flow value or values which are intended to maintain aquatic biota,
usually recreationally and commercially importance fish species, at some acceptable level.
Incremental methodologies refer to a collection of procedures and techniques designed to
predict changes in aquatic habitat due to incremental changes in stream flow and allow the
systematic evaluation of different water management options. Two examples of standard-
setting methodologies are provided. The incremental methodology most relied upon by the
Service is the Instream Flow Incremental Methodology, or IFIM. For small hydroelectric
projects, we have found that standard-setting techniques can be used effectively to set
instream flows in situations where there is little controversy or competition between instream
and out-of-stream uses of water. They are often helpful for long range planning tasks and
evaluating the preliminary feasibility of an applicant's proposal. However, where there is
controversy and competition for water, these techniques do not provide the information
necessary to reach a balance between the need to protect instream resources and the needs
of development. Incremental techniques like the IFIM have helped the Service reach equitable
solutions that minimize the conflicts between these two uses of water and continue to meet
the flow needs of instream resources.
The moderator has asked me to speak today about some of the tools used by the Fish and
Wildlife Service to assess the impacts of hydrological modifications on aquatic communities
and relate to you some of the Service's experiences regarding the formulation of instream
flow recommendations.
My background and experience with hydrological modifications and their impacts on aquatic
resources are related to the development of small hydroelectric power projects in the
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Northeast and the Pacific Northwest. A major environmental issue for most small hydropower
developments is the amount and timing of alterations of downstream water flow caused by
power generation. To evaluate these flow-related impacts, the Service conducts and/or
recommends instream flow studies of the affected stream reaches and, based on those
studies, recommends instream flow reservations for the protection of downstream fish and
wildlife. As a rule, our instream flow studies focus on the protection and maintenance of
habitat for anadromous and other recreationally important fish species with the assumption
that if flows are reserved that provide for the life history requirements of these fish species,
then other aquatic biota will be protected as well.
Over the years, the Service has used a variety of methods to assess the effects of stream
flow regulation on aquatic biota and to provide instream flow recommendations (Bayha 1980;
Stalnaker and Arnette 1976; Stalnaker et al. 1994). These methods differ in their use of
hydrologic records, hydraulic simulation techniques, and habitat rating criteria, and in their
capability to provide seasonal or species-specific recommendations (Loar and Sale 1981).
Research biologists at the Service's National Ecology Research Center in Fort Collins,
Colorado, have divided these methodologies into two categories depending on the objectives
and complexity of the decision process involved (Trihey and Stalnaker 1985).
Standard-setting methodologies refer to those measurements and interpretative techniques
designed to generate a flow value or values which are intended to maintain aquatic biota,
usually recreationally and commercially importance fish species, at.some acceptable level.
Incremental methodologies refer to a collection of procedures and techniques designed to
predict changes in aquatic habitat due to incremental changes in stream flow and allow the
systematic evaluation of different water management options.
Standard setting methodologies are most appropriate for protecting existing instream uses,
state water plans, state water allocation permits or reservations, and identifying target flows
for use during project feasibility studies (Trihey and Stalnaker 1985). Standard-setting
methodologies are usually based on historical water supply records and are relatively easy and
inexpensive to perform.
Incremental methodologies tend to be more complex, time consuming and expensive to
perform. They are organized and repeatable processes by which a aquatic habitat/streamflow
relationship and the hydrology of the stream are transformed into a baseline habitat time
series, proposed water management alternatives are quantified and compared with the
baseline, and project operating rules are negotiated to protect instream resources {Trihey and
Stalnaker 1985). Incremental methodologies are most appropriate for time series analysis to
identify limiting flow conditions, fine tuning resource maintenance objectives, avoiding or
minimizing flow-related impacts, and comparing mitigation or water management alternatives
(Trihey and Stalnaker 1985). Incremental methodologies provide decision makers with
information necessary to facilitate negotiated solutions to complex, controversial water
management problems (Stalnaker et al. 1994).
Two examples of standard-setting techniques that have been widely used by the Service to
recommend instream flows are the Tennant Method (Tennant 1976) and the Aquatic Base
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Water Quality Criteria and Standards for the 21st Century
Flow, or New England Flow Policy (Larson 1981; Kulik 1990). The incremental methodology
most relied upon by the Service is the Instream Flow Incremental Methodology, or IFIM (Bovee
1982; Milhous et al. 1981).
Tennant used over 10 years of personal observations of streams and stream flows in Montana
and the mid-west to categorize streams into varying degrees of habitat quality for fish and
other aquatic biota based on recorded flow data. His method assigns minimum flows needed
to maintain different levels of habitat quality at different times of the year based on
percentages of mean annual flow. Ten percent of the average annual flow is assigned as the
minimum necessary to sustain short-term survival habitat for most aquatic life forms. Thirty
percent of the average annual flow is set as the base flow adequate to sustain good survival
habitat for most aquatic life forms. A base flow standard equal to 60% of the average annual
flow is recommended to provide excellent to outstanding habitat for most aquatic life forms
during their primary periods of growth. This flow level also provided excellent conditions for
most recreational uses.
Tennant's method also sets a standard for periodic high flows to remove silt, sediment, and
other bedload material from the stream channel. A flushing flow equal to 200% of the
average annual flow is recommended as sufficient to produce effective depths and velocities
for moving silt, sediment, and other bedload material without doing extensive damage to
streambanks and riparian vegetation.
The Aquatic Base Flow is a standard-setting technique widely used in the Northeast to
recommend instream flows and is receiving considerable attention by several New England
states as they develop their own biological criteria and standards programs (R. Abele, USFWS,
Personal communication). This method was originally developed by the Service in response
to the "gold rush" of hydropower development activity that occurred in New England in the
early 1980's (Larson 1981). This technique is also based on historical stream flow records
and selects the median flow for the lowest flow month, typically August or September, as
adequate through out the year, unless additional flow releases are required to meet the needs
for spawning and incubation. Where hydrological records are unavailable, instream flows are
recommended on the basis of drainage area. A minimum instream flow value, or base flow,
of 0.5 cubic feet per second per square mile of drainage area (cfsm) is recommended for the
summer months. Flow releases of 1.0 cfsm in the fall/winter and 4.0 cfsm in the spring are
recommended for the entire applicable spawning and incubation periods.
For both of these techniques, the use of stream gage records assumes that those measured
flows support the needs of fish, aquatic insects, riparian vegetation and other aquatic
resources at acceptable levels. This assumption only applies where streams are essentially
undeveloped or where the pattern of development has been stable for a long period (Stalnaker
et al. 1994; Wesche and Rechard 1980).
Where it is necessary to know and understand the response of habitat variables to changes
in flow as a means to support balanced decision making between the need to protect instream
resources and the needs of development, the Service generally recommends that the Instream
Flow Incremental Methodology, or IFIM, (Bovee 1982; Milhous et al. 1981) be applied to
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determine instream flow needs. The IFIM is not a single technique but rather a suite of
methodologies designed to evaluate and integrate the dynamic nature of riverine habitat into
water management practices (Trihey and Stalnaker 1985). IFIM is specifically designed for
simulating and quantifying impacts of changes in flow, channel morphology, or water quality,
resulting from water management or stream channelization activities, on aquatic biota and
instream recreational activities (Armour et al. 1984). It combines measures of habitat quality
and quantity to obtain an index to the amount of habitat available for different life stages at
different flow levels, provides information about habitat changes over time, and provides a
means of comparing the impact of alternative management practices on aquatic habitat
(Stalnaker et al. 1994).
The decision variable generated in the IFIM is total habitat area for the life stages of fish or
other aquatic organisms that are of special concern for management, or that are thought to
be most sensitive to change. Habitat, as computed by IFIM, incorporates longitudinal changes
in channel characteristics, streamflow, water quality, and temperature. These factors are
termed macrohabitat variables, and determine the longitudinal distribution of various aquatic
species downstream. Habitat also includes the distribution of hydraulic and structural features
comprising the actual living space of the aquatic resources selected for evaluation. These
physical features are termed microhabitat variables. Standard microhabitat variables are
depth, velocity, substrate, and cover. The total habitat available to a species at any
streamflow is the area of overlap between available microhabitat and suitable macrohabitat
characteristics.
IFIM uses computer software to integrate these two measures of habitat into habitat units
that are then related to flow over time (Milhous et al. 1990). Displaying the availability of
suitable habitat over time, such as a known period of hydrological record, makes it possible
to analyze the effects of changes in flow on each life stage of every species for which habitat
suitability data are available.
IFIM is not intended to be an ecosystem model (Bovee 1982). However, it is designed to
have environmental and ecological applications. And, unlike traditional standard-setting
techniques, IFIM does not generate a single solution to a flow allocation problem. Rather it
has been specifically designed to provide multiple solutions. However, where habitat
protection and maintenance is a primary consideration, solutions that deviate the least from
the baseline habitat condition can and have been formulated into instream flow standards.
Every instream flow needs assessment that includes instream flow protection offers a unique
challenge (Stalnaker et al. 1994). This is because every assessment presents its owns set
of political, environmental, and institutional problems that directly affect the decision making
process and the ability to defend the decisions that are made. Therefore, there is no single
methodology that can be applied unilaterally to all situations. Rather, the method of choice
should be the technique that provides the most assurance that the recommended flows will
be supportable , sustainable, and capable of protecting a streams biological integrity over a
range of environmental perturbations.
For small hydroelectric projects, we have found that standard-setting techniques can be used
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Water Quality Criteria and Standards for the 21st Century
effectively to set instream flows in situations where there is little controversy or competition
between instream and out-of-stream uses of water. They are often helpful for long range
planning tasks and evaluating the preliminary feasibility of an applicant's proposal: However,
where there is controversy and competition for water, these techniques do not provide the
information necessary to reach a balance between the need to protect instream resources and
the needs of development. In the case of small hydropower projects, there is always
competition because the water needed to maintain instream resources is often unavailable for
power production. Incremental techniques like the IFIM have helped the Service reach
equitable solutions that minimize the conflicts between these two uses of water and continue
to meet the flow needs of instream resources.
Literature Cited
Armour, C.L., R.J. Fisher, and J.W. Terrell. 1984. Comparison of the use of the Habitat
Evaluation Procedures (HEP) and the Instream Flow Incremental Methodology (IFIM)
in aquatic analysis. U.S. Fish Wildl. Serv., FWS/OBS-84/11. 30 pp.
Bayha, K.D. 1980. Instream flow studies and the Instream Flow Incremental
Methodology in water resources planning. Instream flow Information Paper 13. USDI
Fish. Wildl. Serv., Instream Flow Group, Fort Collins, Colorado. Mimeo rept. 44 pp.
Bovee, K.D. 1982. A guide to stream habitat analysis using the instream flow
incremental methodology. Instream Flow Information Paper 12. U.S. Fish Wildl. Serv.
FWS/OBS-82/26. 248 pp.
Kulik, B.H. 1990. A method to refine the New England aquatic base flow policy. Rivers
1(1):8-22.
Larson, H.N. 1981. New England flow policy. Memorandum, interim regional policy
for New England stream flow recommendations, U.S. Fish and Wildlife Service, Region
5, Boston, Massachusetts. 3 pp.
Loar, J.M. and M.J. Sale. 1981. Analysis of environmental issues related to small-
scale hydroelectric development. V. Instream flow needs for fishery resources.
ORNL/TM-7861. Oak Ridge National Laboratory, Oak Ridge, Tennessee.
123 pp.
Milhous, R.T., J.M. Bartholow, M.A. Updike, and A.R. Moos. 1990. Reference manual for
generation and analysis of habitat time series - version II. U.S. Fish and Wildlife
Service Biological Report 90(16). 249 pp.
Milhous, R.T., D.L. Wegner, and T. Waddle. 1981. User's guide to the Physical Habitat
Simulation System. Instream flow Information Paper No. 11. U.S. Fish Wildl. Serv.
FWS/OBS-81/43. 254pp.
Stalnaker, C.B. and J.L. Arnette, editors. Methodologies for determination of stream
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resource flow requirements: An assessment. U.S. Fish and Wildlife Service FWS/OBS-
76/03, Washington, D.C. 199pp.
Stalnaker, C., B.L. Lamb, J. Henriksen, K. Bovee, and J. Bartholow. 1994. The
instream flow incremental methodology: A primer for IFIM. National Ecology Research
Center, Internal Publication. National Biological Survey. Fort Collins, Colorado. 99 pp.
Tennant, D.L. 1976. Instream flow regimens for fish, wildlife, recreation and related
environmental resources. Fisheries 1(4):6-10.
Trihey, E.W. and C.B. Stalnaker. 1985. Evolution and application of instream flow
methodologies to small hydropower development: An over of the issues. Pages 176-
183 in F.W. Olson, R.G. White, and R.H. Hamre, editors. Proceedings of the
symposium on small hydropower and fisheries. The American Fisheries Society,
Bethesda, Maryland. 497 pp.
Wesche, T.A. and P.A. Rechard. 1980. A summary of instream flow methods for
fisheries and related research needs. Eisenhower Consortium for Western
Environmental Forestry Research, Water Resources Research Institute. Eisenhower
Consortium Bulletin No. 9, University of Wyoming, Laramie.
122pp.
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Water Quality Criteria and Standards for the 21st Century
ADDRESSING HYDROLOG1C MODIFICATION AND HABITAT LOSS
David P. Braun
Hydrologist Water Quality Specialist
The Nature Conservancy
Arlington, VA
Abstract: Methodologies and approaches to assess the impacts of hydrologic modification
on aquatic biota and their habitat—Eastern perspective. Wetlands hydrology—gw/sw
interaction. Monitoring for ecological significance (on limited resources)—how set monitoring
objectives and endpoints.
Panel Comments:
My comments will necessarily be brief and general given our time limits but will touch on
several issues raised by the speakers and other discussants. Other speakers from The Nature
Conservancy will discuss some of the specific experiences and views of our organization later
in this conference.
The Nature Conservancy is in the business of protecting biological diversity in our increasingly
human-dominated ecosystems, and is widely involved in the conservation of riparian, aquatic,
and wetland ecosystems. These overarching concerns drive our interest in the ways that
water quality criteria and standards address issues of hydrologic modification and habitat loss.
My comments here will cover the general philosophy that informs our concerns and
conservation efforts.
We recognize that protecting biological diversity in the face of hydrologic modification and
habitat loss is not possible to the same degree everywhere. We often must make choices
about the biological values we seek to protect. Wherever possible, though, protecting
biological diversity—as opposed to protecting only a few select species—must involve
protecting ecosystem structure and function. This in turn, necessarily involves protecting the
integrity of the physical processes that shape this structure and function.
The key physical processes shaping riparian, aquatic, and wetland ecosystems are hydrologic
and hydrogeologic processes. These processes involve atmospheric, surface, and ground
water; and also can involve the exchange of water and water-borne substances among these
three environments. That is, the movement of ground water into streams and wetlands, and
the leakage of water from streams and wetlands into the ground water can be important
components of the hydrologic system in many ecosystems. Ecological conditions at individual
sites are shaped by these key hydrologic and hydrogeologic processes operating at several
spatial scales — at the immediate sites, within their local drainage areas, across their entire
surrounding watersheds, and across entire ecological regions.
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The key physical processes combine to produce the hydrologic "regime" of any given site.
This regime consists of the patterns of water availability, velocity, turbulence, temperature,
and concentrations of dissolved and suspended constituents, these conditions vary over time.
Further, in order to fully characterize it, we must describe the hydrologic regime in terms of
the timing, duration, and frequency with which different conditions occur - both their
averages and their ranges of variability. Hydrologic regimes thus include much more than
simply the average annual or monthly water depth, stream flow, sediment load, or salinity at
a given site.
Hydrologic regimes also include variability on many time scales, and include not only the
"normal" range of conditions at a site but also the "extremes" of floods, droughts, other
infrequent conditions. However, from an ecological standpoint there is nothing "abnormal"
or undesirable about these extremes. They are a natural and indeed often a crucial part of
ecosystem dynamics, especially long-term historical dynamics. Indeed, we must bear in mind
that ecosystems are naturally dynamic; they have evolutionary histories and capabilities, and
are never static in either structure or function.
Ecologists have increasingly come to the realization that species survival, reproduction, and
interactions in water-dominated ecosystems often depend intimately on specific and even
unique features of the hydrologic regime. These relationships often can be very subtle and
different from one species and ecosystem to the next. As a result, when you seek to protect
biological diversity, it is very difficult to segregate any single feature of the hydrologic regime
as more important to ecosystem function than any other. These features can include aspects
of both the normal and extreme ranges of variation in the hydrologic regime at each site; and
can involve threshold effects, in which a slight change in a single feature of the regime can
cause large changes in ecosystem structure and function.
For example, even slight changes in the timing of high or low turbidity in a stream can make
a great difference in the ability of some fish to mate, or the ability of many fish and shellfish
to feed. Slight changes in the pH or temperature of stream water can have similar effects.
Changes in the frequency, timing, or duration of flooding can cause changes in streambed
habitat and in floodplain vegetation, as well as in the movement of nutrients between the
floodplain and the stream. A stream that has lost its ability to flood or to scour its banks can
become a biologically very different place indeed. And even small changes in the chemistry
of waters entering many kinds of wetlands can cause enormous changes in vegetation, as can
changes in the. timing and duration of wetland flooding and drawdown.
Given this intimate relationship between hydrologic regime and ecosystem processes, water
quality criteria and standards that address biological diversity and ecosystem integrity need
to be developed with the following considerations:
First, we need to recognize that human activities can alter hydrologic regimes in many ways:
Stream, lake, and ground water withdrawals, and hydropower and flood control
systems are only the most obvious examples of hydrologic alterations. These
usually are monitored routinely only for their effects on water availability,
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however, leaving their impacts on other features of the hydrologic regime less
often examined by and large.
Other examples of activities that affect both surface and ground water
availability include alterations of surface runoff rates and patterns by pavement,
buildings, and agricultural practices; alterations of vegetation by land use
practices and fire suppression; and the drainage of wetlands.
Water chemistry and temperature regimes can be altered not only by the well-
recognized impacts of point and nonpoint discharges, but by changes in the
capacity of watersheds to exchange natural nutrient materials between streams
and riparian zones; in the rate and timing of ground water discharges to streams
and wetlands; and in the contributions to stream flow from geologically
different tributary watersheds.
Thus, we need extensive knowledge of entire watersheds and an ability to model watershed
processes, in order to know how, and to what extent, any given human activity has affected
or will affect a site's hydrologic regime.
Second, we need scientific tools that allow us to measure the extent of alteration to
hydrologic regimes that has or will result from our activities, and will allow us to distinguish
human-caused alterations from natural variation. Given the subtleties of ecosystem
interactions with hydrologic regimes, measurements of such gross parameters as average
flows, temperatures, or salinities will often be no more useful than measurements of only
average pollutant or sediment concentrations and loads. Similarly, given the subtleties of
ecosystem interactions with hydrologic regimes, management tools such as the IFIM fall far
short of providing the information needed for effective ecosystem management. Indeed, we
need scientific tools in combination with better ecological knowledge, so that the features of
the hydrologic regime that we do monitor are the ones most ecologically significant rather the
ones easiest to measure.
The Nature Conservancy has developed and begun testing and improving a method called the
"Index of Hydrologic Alteration," that provides a means to assess the impacts of human
activities (and climatic change) on hydrologic regimes. The method captures information on
alterations to several of the most commonly ecologically significant features of water
availability regimes. It requires reference data on pre-impact conditions, or surrogate pre-
impact data, for comparison. We feel strongly that such tools have an important role and fill
an important need in our efforts to protect biological diversity.
Third, we need legal tools that allow us to recognize and deal with ways that our activities
in any one part of a watershed can affect the hydrologic regime in other parts of the
watershed. These tools should allow us to recognize and deal with the ways by which
impacts on ground water conditions can affect surface water conditions and vice versa, often
over considerable distances. Legal doctrines that do not readily recognize the
interconnections between surface and ground water systems, or that work against regional-
scale hydrologic planning efforts, for example, can pose unique challenges to our efforts to
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protect riparian and aquatic resources.
Finally, we need a framework that recognizes the sometimes subtle but crucial relationships
that can exist between many features of the hydrologic regime and ecosystem structure and
function. These relationships often can be unique to particular sites or ecosystems, and can
pivot on subtle aspects of the hydrologic regime. Managing an ecosystem for hydrologic
conditions that support a limited suite of species may leave other aspects of the hydrologic
regime vulnerable to alteration and so allow the ecosystem to degrade despite our best
intentions.
In sum, we need planning tools and assessment methods that include but also focus on much
more than the health of small numbers of species as indicators of overall ecosystem health.
That is, we also need planning tools and assessment methods that include evaluations of the
physical processes — especially the hydrologic regimes — necessary for ecosystem integrity.
We need legal tools that recognize the relationships that can exist among surface and ground
water processes across entire watersheds. And we need management tools that recognize
the often subtle and crucial importance of hydrologic regimes in ecosystem function.
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Water Quality Criteria and Standards for the 21st Century
SESSION 2: QUESTIONS AND ANSWERS
Q: Will innovative approach eclipse or conflict with existing WQC&S?
A: No, the innovative approach is to add to EPA's tool box (Susan Jackson)
A: We do not see this as a competition (Estyn Mead)
/
Q: Is FWS's philosophy to give EPA the lead?
A: No, work as partnership. (Mead)
Q: How do we deal with artificial ecosystems that arise from water use (e.g. irrigation
return flow and WWTP discharges) in terms of WQS? (Mark P, Colorado Springs)
A: Artificially induced systems are one of our most difficult issues. Some of the systems
developed may be worth saving (e.g. artificial wetland may be valuable habitat) and
we may need to make a decision that it is beneficial and must be protected. It is a
very site-specific issue. Currently under wetlands there is no distinction between
natural and artificial wetlands. This may change in the future. (Max Dodson)
Goal of EPA is to get the State to do the right thing. It is the State's prerogative with
EPA there to provide funds and support.
Q: Have there been other stakeholders involved in San Joaquin watershed issues debate?
What are the sociological values being dealt with? (John Jackson, Oregon)
A: State held public meetings (water rights meetings), 1 74 interested parties, agriculture,
urban, 84 attorneys involved. An average of 50 representative attend each of these
meetings. State tries to have a workgroup and get the stakeholders to develop a
negotiated solution and bring it to the State. Historically, most progress in setting
standards has been achieved when stakeholders are present and the workgroups
develop a negotiated solution plan which the State adopts. (John)
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Comments
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Water Quality Criteria and Standards for the 21st Century
INTRODUCTION OF ROBERT PERCIASEPE
Tudor T. Davies
Director, Office of Science and Technology, OST
U.S. EPA
We have to get back into the energy level that we had yesterday. A couple of comments on
the day. I have asked our session moderators to make sure that the presenters stay within
their time limit. One of the things that we need to do better today than we did yesterday is
embark upon a dialogue among ourselves. Many of the things that we are talking about,
particularly from an EPA, a city, and a state standpoint, are things we want to hear some
response to. What I would like you to do today is comment. Yesterday a number of people
that came to the microphone asked pointed questions to EPA. I think you can do that
individually to many of us that will be here right through the conference to get EPA's answers
to those questions. What we'd like to know is what your answer to that question would be.
You have a particular perspective, I talked to Bob Berger who asked a question about anti-
backsliding and anti-degradation. What I would have liked Bob to do is say "This is what I
think about those two issues, what do you think?", so we can have a dialogue. We need your
input. I would like to see a line of people at the microphones who want to talk, and share
their ideas, that's the benefit to us. We want your input, if you don't get a chance and there
are too many lines* perhaps when we go into these breakout sessions today there may be
more opportunity for dialogue. We ask the presenters to be provocative, to be short, to be
to the point, and then we can have dialogue so that we can get the feedback from you about
these ideas that we are investigating and talking about.
If you remember at the last conference that we had in Las Vegas we talked about ideas, we
talked about alternative positions, we are moving toward some ad Hoc positions that came
out of that meeting, we'd like some response to those positions. So please talk. At the
breakout sessions we will have staff in each one, we want to know what you think, what
your problems are, what your ideas are, I would prefer you do that rather than ask EPA
pointed questions that may be of relevance to you particularly, but perhaps not to the total
audience. If you do have a question like that, tell us what you think the answer should be, so
we can get your perspective as well. Anyway that's a heavy way to start. Please do
communicate with us, I do think that is the whole purpose of the meeting.
Today I have the great pleasure to introduce Bob Perciasepe, who is the Assistant
Administrator for Water. Bob has been with us for just about one year in his formal position.
He brings extensive experience from a state environmental program. And, perhaps for the
Office of Water, he brings a broader experience than we have had in a number of years, in
that he ran the whole set of environmental programs for the State of Maryland and came to
that program with experience in working in city government at various levels. He was also
a prime mover in the Chesapeake Bay program, that you heard Rich Batiuk talking about
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yesterday. So he brings to the Office of Water a perspective on how the Federal government
works from a state and city perspective, how we respond to the public, how we should
change. And he also has been a major mover in the ecosystem program from the state level
and from the national level.
His perspectives have been very useful to us. He has made us stop and think about the way
we do business. He has been a strong arm for the Administrator and you heard yesterday
how much she thinks of the Drinking Water and Clean Water Act programs. And so I think
we'll all enjoy hearing some of his perspectives this morning on where he sees the water
programs going.
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Water Quality Criteria and Standards for the 21st Century
WATER QUALITY CRITERIA AND STANDARDS FOR THE 21ST CENTURY
OPENING COMMENTS
Robert Perciasepe
Assistant Administrator, Office of Water
U.S. EPA
Good morning everyone, I hope you all weren't up too late last night, and that my talk at least
gets you going a little bit. Yesterday you heard the Administrator and her vision on some of
these issues, some of the challenges she is facing. I think these are challenges in the
environmental field that we all face. And, I think during yesterday's sessions you heard a little
bit about the tools that are needed for ecosystems management and how the water quality
standards and criteria program is evolving into the 21st century. I couldn't think of a better
title for the conference than that because it is an evolutionary process that is taking place.
Most of you here today are on the front lines of environmental management, and I think you
look to EPA to provide some leadership, some guidance, and above all some tools for you to
do your job. And that is what we hope we can do and that is what we want to do. One of
the purposes of this conference is to share ideas, so we can be in a better position to do that.
I won't read much into Tudor's comments about pointed questions. I imagine that there were
some.
Tudor also mentioned that in my past life I worked on the Chesapeake Bay. I wouldn't say
that I was a prime mover, but I certainly had the honor to participate in that rather extensive
program that in many respects is a model for looking at how environmental programs work
on a place, as opposed to as a program perspective. I think there was an interesting lesson
that I learned. Probably the best lesson I learned was that the public by in large does not look
to how many milligrams per liter of some chemical or some compound in the water column
as the indicator of whether the program is successful or not.
What they want to know is, can they can go fishing for striped bass, or rock fish? Will there
be crabs for the 4th of July? And, when they're out there in their boats, can they jump in the
water. These are the environmental indicators that the public use, and to a certain extent the
ones the media use.
Our job is to translate our technical needs in science into those kinds of measurements that
the public understands, the public can rise to the challenge of, and the public can buy into so
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they can make the hard choices, to make it happen when they decide that this is what they
want.
Another key message that Carol had and one I would like to bring to you is that moving
towards an ecosystem or watershed management approach means involving the stakeholders.
Stakeholders are primarily the public and entities that are involved in decisions that effect the
work and the way life is conducted in a watershed. But those stakeholders have to have some
common view of where they want to go, or what they want to do. For example, if, they
want to be able to fish for rockfish, then that's one of the things that has to be factored in
as to how we do our business in the water quality management world.
Now these are not unusual thoughts, nor are they foreign to most of you. But they are
challenging and it's these challenges that we need to adapt to and change the way we think
in terms of implementation.
We proposed improvements to the Clean Water Act earlier this year. And I guess the
Administrator told you that the Clean Water Act is not going to be passed by Congress this
year given that they have about three weeks left, maybe four weeks left in the session. There
is actually no debate going on about it right now so I don't think we're going to be seeing a
revised Clean Water Act this year. We had a number of issues that we were pressing for in
the Clean Water Act. Some had to do with shoring up some of our existing programs, like
the non-point source program, wet weather flows with CSO's, expanded enforcement
provisions, as well as increasing and reauthorizing the state revolving fund that provides some
financial tools.
Some of the issues that we also were looking at include some of the subjects of this
conference. For example, we proposed new approaches for how to do water quality
standards, whether we should be looking at the bioaccumulative and persistant toxics, how
we deal with watershed approaches to water quality management and tying that together
with the different programs.
These are new directions that we have been working on, that are going on around the country
and that we wanted to get a statutory framework in which to work under. That's not going
to happen this year. So we are going to have to work harder yet with our existing tools to
make some of these transitions, because I suspect the debate on the Clean Water Act is going
to go on for many years, based on my personal knowledge of the state of the debate at this
particular time. There is really no convergence of opinion on the more critical issues.
We can't abandon the base that got us where we are. We can't abandon the good-point
source programs that have gotten us where we are, but we do need to start looking about
where we are going.
Last week I spoke to an environmental finance conference at the University of Maryland.
Interestingly enough the same kind of sea change thought process is going on there as is
going on with a lot of the water management programs in the country. Now that we know
more about non-point sources and wet-weather flows, problems and factors like habitat
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Water Quality Criteria and Standards for the 21st Century
considerations and harvesting are key in defining a healthy ecosystem; the vehicles for
financing programs to solve these new problems hasn't kept up with our improved
understandings of what the environmental programs should include. Financing techniques are
still imbedded in point-source programs. Fees, user charges, none of those systems work
very well to solve some of the more intractable problems.
Likewise, our criteria and standards, our under pinnings of science, have to also flow into an
implementation tool development mode that follows what we understand the problems to be.
That is a very difficult challenge, one that we have to continue to focus on, and one that I
know is a focus of this conference.
Getting all of our programs at EPA together a little more harmoniously is something that we
are working very hard on. There are two major areas that the Administrator and the rest of
the leadership at the Agency is pushing very hard on. I think she mentioned both of them
yesterday but I will try to talk a little bit about both of them today.
First, what we call the Common Sense Initiative. This is an initiative that is looking at the
regulated community. How do we deal with the regulated community holistically across the
board and up and down through levels of government. If we are dealing with the iron and
steel industry, it's not just the air program, it's not just the water program, it's not RCRA.
It's all of them together. It's not just the federal government. It's also the state government
who probably have more inspectors visiting the steel mills than the federal government does.
If they are using water or discharging to a sewer system they are probably actually involved
with the local government.
It's a whole host of regulatory environments that a steel mill is subjected to that transcends
level of government, transcends programs. In addition, there are a lot of stakeholders that
have an interest in what happens at steel mills. Labor unions, environmentalists, the levels
of government I mentioned, the suppliers and the customers; all of these people have a stake
in what happens at steel mills. What we have found, and I'm using steel mills as ah example,
that as soon as we try to regulate any particular sector we find out very quickly what all those
other stakeholders think about what we are doing. The supplier says, "well I won't be able
to get my product the way I want it any more because they won't go all the way to make it
bright," (as you used to hear with the phosphate debate). Remember those? Those were the
good old days, before anything could bioaccumulate. Then it was biodegradable. The whole
issue of how do we deal with a regulated community holistically is one we are struggling with
and why we've kicked off this initiative. We are looking at six industrial sectors—auto
assembly, electronics and computers, iron and steel, metal plating and finishing, petroleum
refining (that's an easy one), and printing. That runs a gamut from your high tech to your
traditional smokestack industry. It also runs a gamut of small businesses to big large
integrated steel mills. So you've got a real spectrum of what we're doing there. We're
putting together teams of those stakeholders that I mentioned on each one, and they are
going to examine six specific areas, and take a fresh perspective of the regulations that we
currently have in place, prospectively and retrospectively. They are going to take a look at
how these things are working together. This is going to provide a context for our regulatory
review, which we are required to do by Executive Order-look at our regulations and see how
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they are working. You just can't wheel them into a room and say, "hey O.K. lawyers, lets
have at it." Unless you have a context. What is the context? What isn't working and what
is working and are they working together? Should they work together? We're going to look
at pollution prevention. We're going to look at information collection. There's RCRA and
NPDES; and the new clean air protection systems-they all are going to provide the same
information. Can it be integrated? Can it be modified? Can it work better?
I don't know what the answers to the questions are but we're going to ask them. Strong
enforcement and compliance assistance is also a part of this initiative. How do we factor that
in? How do we improve the permitting process? We have a permitting improvement team
in place. These sector teams are also going to look at the permits in the context of the
different sectors. How can the permit process be made more efficient? We're also going to
look at the barriers to new environmental technology and, again, we will have teams made
up of the stakeholders involved. Each team will be chaired by an assistant administrator and
a regional administrator, with a state environmental commissioner as a lead for the states.
We've already started these meetings. In fact, I chaired the first iron and steel meeting
yesterday. We had people from all over the country. So this approach as we develop it, will
be a way to integrate our programs up and down the government structure and across the
EPA media structure, and one that we hope will bear fruit.
At a minimum if the EPA, state, and local regulators understand more about the people we
regulate and they understand more about what we have to do and that's all that happens, I
think we will have made progress. But I hope that, and we expect that there will be a lot
more coming out of this initiative than that.
The second area that we are pushing and pushing very hard at the management level in EPA
to integrate our programs, is something we call ecosystems management. Although we are
struggling for a better term than that because the term "ecosystem management" doesn't
mean much to the general public. Another thing that we've been talking about is place-based
environmental management. The key here is how do our programs work up and down the
government structure, across the media to deal with a place in the real world that needs to
be clean. Just as we have a process for looking at those we regulate holistically, we also are
starting a process that looks at the places we want to protect or clean, or restore holistically.
I'll use ecosystems management today as a way to describe that process. It's a process that
recognizes that one-size-doesn't-fit- all. You've heard some of the examples of place-based
environmental management that are already in place, where there is a lot of watershed
activity going on. Source protection for drinking water or groundwater protection programs
are looking at places, and there are others I'm sure that we can think of.
The idea here is to link our programs to fundamental strategic choices. To look at what the
place needs in terms of its goals, keeping in mind the base of our existing statutory
responsibility. We have to look at ways that we can do this creatively and flexibly. We have
to look in each place to find the problems, set priorities and help with solutions. "That is what
the stakeholders can do if they buy into the solutions. This is another example of getting
folks to the table-the different levels of government and the different people who have an
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interest in an area-into the solution.
Water Quality Criteria and Standards for the 21st Century
We'll be turning more and more to this type of an approach in the agency. And we'll be
looking at more places and involving more people in what we do. This still has to be based
on sound science, and this is where you come in. The tools that we are going to need to do
this can be presented and can be dealt with in a digestible way, but they have to be based
on sound underpinnings. We can't be making up the goals, but we have to be figuring out
if they are achievable, how they get achieved and what's the science behind them. I think
the EPA is in the unique position to provide that kind of leadership and those kinds of tools
and I think that that's what we should be doing.
We're looking at our regional offices to be what we call our place rangers. We have 10
regional offices around the country. We want them to be facilitating and creating the
environment for these activities to take place. To be engaging. To be pulling people literally
out of the woodwork to participate in various place-based environmental management
activities. And we will have, or we hope we will have, because we still haven't gone through
the1 full budget process, a major initiative for our 96 budget that we'll be shifting resources
to regional place-based environmental activities.
One of the foundations for doing this, obviously, is going to be some new tools, and adjusting
the tools we currently have to meet the needs that I was just talking about. I'm still talking
about ecosystems management.
Here are some of the things that I hope you'll be thinking about during and after this
conference. Some of the tools that I want to say something about are:
Environmental Indicators, Habitat Assessment and Sediment Criteria, Biological Assessments
and Nutrients Methodology, to just name a few.
Environmental Indicators. How many of you have heard the term "you can't get there
from here?" Right, I actually saw a cartoon that said the same kind of thing. One of those
little cartoons, probably Larson or something, where there was a guy standing on the side of
the road and a guy sitting in a car. There was a big sign next to the guy that said "Point B',
and way off in the distance across the desert that you could hardly see was another sign that
said "Point A." The caption at the bottom said "I don't know mister, no one ever asked that
question before." You know, "how do you get from Point B to Point A?" We always say
"how do you get from Point A to Point B" and the question is, "what are these indicators?"
How do we tell when we get there in environmental improvement, what's the answer? Is it
the milligrams per liter, or is it the rockfish? Is it acres of aquatic vegetation for habitat? Is
it a number of obstructions to spawning? Is it swimmable beaches? Obviously it's all those
things. The kinds of measures we use these days are significant non-compliance, average
monthly whatever. I don't want to say something that will technically be wrong with you
people here, but you know what I mean, and these are important and we have to have them.
But how do we take that next step to engage the public, engage the stakeholders into figuring
out what they want.
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I can take you places within driving distance from here, where everything is in compliance
with everything. There are no NPDES permits out of compliance. All of the construction sites
have the proper sediment control. You name it, everything is in compliance. Yet the ecology
of the stream is degrading. How do I know that the ecology of the stream is degrading?
Because I go out there and I can tell that the species diversity is down, the abundance is
down, the temperature is up, there's no habitat, there are no amphibians. Whatever measure
you want to use, something's wrong in that stream. But yet everything's in compliance.
There's another problem we have to deal with. What are we missing and is it in the purview
of EPA, this thing we're missing? And if it's not in the purview of the EPA then whose purvey
is it in? And how do we factor it into ecosystems management? It is very important, is how
do we get those measures, how do we find those indicators and what are they and that they
be based on science. I think that the question on how do we get from Point B to Point A, or
alternately create a Point C, and we'll all go over there.
Public participation is important in this process because you have to be able to communicate
back and forth and get an understanding of what the public wants. We have to be able to
translate to them what it is we're talking about, because ultimately whatever we're talking
about in environmental improvements is going to mean spending money or resources. It could
be time, it could be flexibility, it could be money, but there are going to be resource
expenditures.
People are going to have to make decisions, and choices. Elected officials are going to have
to make decisions, and choices. The more they understand what those choices are buying and
where they want to go with them and what the indicators of success are going to be, the
more willing they are going to be to make the investment.
When you do public opinion surveys, 70 to 80% of the people still say we're not going far
enough, because they have some indicator in their mind. Whatever it is, they've got it in their
mind that we haven't gone far enough. Yet when you go to congress or to state legislators,
and I've been to both of them, we're spending to much money on this stuff; we don't know
what we're getting etc., etc., etc. So there's a disconnect; there's something in the public's
mind we're not going far enough, wherever that is.
Where is Point C? In the elected officials mind they're making these tough decisions about
money and they got these conflicting interests coming to them. It's easy for the public to say,
I want no crime; I want all this health care; I want everything in the environment to be fine
and I want to be able to drive my car where ever I go. That's what they'll say, so you take
that with a grain of salt perhaps in terms of public opinion. But clearly the public has some
vision that hasn't been satisfied. We see this time and time again in the polls. Yet, the
congressional, state legislature, the executive branch decision-makers are making allocations
of resources as well as the boardrooms of this country are making allocations about corporate
investment. All are saying, well, wait a minute, what are we getting, where are we going?
Why are we going there? And so tough decisions have to be made, buying has to occur, and
that's where translating- some of the things we do for a living into these indicators is
important.
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Water Quality Criteria and Standards for the 21st Century
Habitat Assessment. How do you, I just went through something, species abundance,
species diversity, does that mean anything? Is it different in a stream in Arizona from a
stream in Virginia? Probably yes. So how do we do that? How do we determine whether
or not the habitat is there for the needs we have? Do we spend another billion dollars
cleaning up the Chesapeake Bay so that we can have shad? Or do we simply remove the
barriers so they can spawn? You know, so they can have spawning habitat. What a concept.
You know that may be a hell-of-a-lot cheaper than spending another billion dollars thinking
that it's pollution we are dealing with, so we have to link these things together in a way that
we haven't been successful at in the past.
Nutrients. This has been a struggle for many years. People have looked at all kinds
of approaches in dealing with nutrients, classifying lakes as eutrophic levels. We need a
place-specific way to do this that is linked to some of these indicators. Maybe it's submerged
aquatic vegetation. Maybe it's light penetration. Maybe its chlorophyll-A or the amount of
algae. Whatever. What's a good nutrient environment in terms of photosynthesis in one area
may be different than another area. And, part of the answer to what the nutrient criteria
ought to be, I think, probably ought to have a place-based component to it. Obviously it's
different in a stream than it is in a lake. And in an estuary than in an ocean. We have to
consider all that and figure out ways to apply it.
Sediment Assessments. How do we look at whole sediment toxicity? How do we deal
with that in terms of the benthic community?
Risk Assessments. How do we integrate these tools into ecosystems management and
communication devices to the public? That's something that we have to do. That is
something that you can help on. How do we create a package, a toolbox so that we do know
how to get to Point C? And again, case studies are being developed. There are case studies
that you are going over in this conference, there is a lot of activity and a lot of energy in many
of these areas. I think to get to the next level of water pollution control in this country we
need to figure out how to take the science and the new understanding of what the water
quality problems are, put those together, develop the tool box and the indicators and how to
get there, develop better tools on communicating with the public as to what their expectations
are. It is no longer simple; it is no longer secondary treatment at every plant. That was good;
it was great; it got us a long way; it is easy to digest; and everybody understands it. I won't
get into the ways though, but we did it.
The next part isn't that easy, fifteen percent submerged aquatic vegetation in every estuary.
How about that? Nobody knows, so it is going to be different in different places and we
again have to link it to science. If I can leave you with this thought, the leadership at EPA,
I think that the leadership in state government where I come from, leadership in corporate
America, leadership in community activists, leadership in tribes, they all want to figure out
ways to integrate our program to get to that next level. I haven't heard anybody say "no, Bob
that is a bad idea." I don't want to go to Point B; been there; saw that; did that. I've heard
people say we need to get to the next level, but we need to be a little better at answering the
questions of what we're getting, how we're getting there, and what's the indicator of success
when we get there. It can't just be we spent 50 billion dollars and now everybody's got
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secondary treatment. It's much more complicated than that and there has to have a scientific
basis to it. The challenge we face in the Agency is dealing holistically with the regulated
community to get the most we can get out of that relationship, dealing holistically with the
places we want to clean, and getting the most out of stakeholder involvement and getting a
scientific understanding of what needs to be done in that place. That is the challenge we face
in environmental management, and you all are in a unique position to help develop and move
us forward in meeting these challenges.
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Water Quality Criteria and Standards for the 21 st Century
QUESTIONS & ANSWERS: OPENING COMMENTS (Perciasepe)
Q. What do you do at EPA if you find, you mentioned that if it's not in the purview of
EPA, or looking at if its in the purview of EPA, what do you do if the stressor that you
are looking at is not in the purview of EPA, what do you do? For example: Let's say
you find out that you find out that over fishing is really the cause of the decline of
fisheries, and EPA doesn't regulate fisheries.
A. I think that was the point I was trying to make with place-based or ecosystems
management that the stakeholders have to be involved, including the Department of
the Interior, local fisheries commission or whoever who have some stake in that, as
well as the public, the commercial and recreational fisherman or fisherpersons or
whatever and they all have to understand what the problem is. What we had in the
past, and I observed this, and I said it during my talk, sometimes it's convenient to
say, "well there's still environmental problems and we need more in pollution control."
And sometimes it's stabilization on the pollution side and management of the living
resources both from a habitat and harvest standpoint. I think that the only way you
are going to get that is when you look at a place. There is no one federal agency, no
one state agency, no one local agency, or tribe that has the total absolute purview
over all the factors involved. There may be things outside the reservation; there may
be things upstream in another state; there may be air deposition, and there could be
harvesting as regulated by different agencies. So the idea is to get everybody to agree
on what the plan is and what the approach is and then you get the cooperation that
you need. That's sort of the beauty of doing ecosystem or place-based environmental
management. That's also the challenge because I don't think anybody wants all this
authority to be vested in one entity.
Comment: Now, my comment. I agree with you 100%, you see the problem with EPA in
the past has been, they see their charge as doing everything. And I think what
you are saying is you should facilitate everything; you don't have to do it all
yourself, and you should try to get it done, and I think that's where this idea
of getting the states involved and helping. For example, the use where EPA
could facilitate that, but they don't have to do it all. That's my comment.
r
A. Yeah, well I hope we're facilitating that in California. In very interesting ways.
Q. Jon Monson: City of Hollywood, Florida. I will make a comment rather than a pointed
question. You really hit a cord with us, especially your comment on everything's in
compliance but the ecosystem seems to be degrading. Let's look at the flip side.
What if everything's in compliance; you see no degradation but you are being asked
to do more. Quite frankly, what we have here is the need to define the problem. And
I'm really impressed to hear EPA's approach to this. I am really concerned in how we
define those problems. I'll make a comparison here. We're being asked in South
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A.
Florida to remove silver from bur wastewater. Now silver is a problem, but when you
look in the environment we don't see where the problem is occurring yet we're being
asked to do more and more. So when we come up with something as simple as silver,
and when I say simple, that's with a grain of salt, because I've gotten lab results that
tell me the ocean has got about a part per-million in it of silver. And I go back to them
and I say come on, and they say oh-yeah we forgot to account for the chlorides in the
ocean and they come back with real silver numbers. Now I compare that with
something as simple as silver to something as complex as, "how do we measure
habitat," and the criteria that are going to be established for habitat are going to be
much more complicated than an EPA method for measuring silver. Yet the people are
going to be required in meeting that goal or criteria. I would like to commend EPA for
bringing the regulated community into this entire process. I am also very pleased that
the environmental groups are going to be involved in this because they seem to be our
primary focus for getting the message out. What are the important problems? If we
can focus them on what consensus is of what the important problems are, I think we
are going to go a long way.
I appreciate the comment. I know we continue to work on silver and other chemical-
specific and pollutant-specific issues. They are not going to go away, keep in mind
that whenever I was talking we need a base on which to hop off on maybe that base
can be adjusted as we are working with our common sense initiative, but the base has
to based on science. Another example of the bioaccumulative toxics where there may
not be an immediate habitat or living resource problem yet there is a systemic
ecological problem that has to be dealt with so decisions have to be made on a broader
sense. You can point to the DDT decisions of the past that were affecting a whole
host of organisms on the earth and continued to in some places in the world. And
there are probably more problems like that, but there are always exceptions to the rule.
and there is always a reason that you need to focus on one thing or another. But as
a general rule, the framework that I laid out is where we need to go in the next decade
as the transition that is logical based on science and based on sound public policy and
involvement. So it is a challenge and there will be back and forth. So I do appreciate
those comments.
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I
Session 3
Assessing Risk At
The Watershed Level
Integrating Assessments to Solve
Complex Problems
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Water Criteria and Standards for the 21st Century
ECOLOGICAL RISKS AT THE WATERSHED LEVEL: INTEGRATING
ASSESSMENTS TO SOLVE COMPLEX PROBLEMS
Suzanne K. M. Marcy, Ph.
Biologist, Health and Ecological Criteria Division
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
Session Moderator
The U.S. Environmental Protection Agency and the Office of Water have identified watershed
ecosystem protection as a top priority. To meet this challenge, we need to use available
assessment tools in more integrated and innovative ways. We need to develop a new process
that allows us to evaluate and predict ecosystem vulnerability to diverse human activities
impacting watersheds and placing them at risk.
Assessment of ecosystem level risk can be based on current ecological risk assessment
methodology as described in the Framework for Ecological Risk Assessment (USEPA 1992).
Ecological risk assessments contain three primary components: problem formulation, analysis
(encompassing characterization of exposure and ecological effects) and risk characterization.
These basic principles are now being modified and expanded to develop a scientific process
for assessing risk at the watershed ecosystem level. Principal differences identified in the
process include the high level of manager involvement required, and a primary focus on the
ecological resources to be protected.
To develop the process, a multi-agency Technical Panel, co-sponsored by the USEPA Office
of Water and Risk Assessment Forum, was established in 1993 to develop case study
examples of watershed level ecological risk assessments. These case studies are featured in
Session 3. Although each case study watershed is subject to complex interactive problems
from many sources of stress, the five case studies will be used here to target some of the
more difficult issues facing watershed managers today. For example, endangered mussels in
the Clinch River Valley, VA, are already being carefully managed but they continue to decline.
Big Darby Creek, OH, is a relatively unimpaired ecosystem subject to increasing land
development. In the Middle Platte River, NE, farmers working in America's agricultural bread
basket compete with the birds of the Central Migratory Flyway for a limited supply of water
and wet meadows in a complex hydrologic system. Waquoit Bay Estuary, MA, is suffering
the effects of over-enrichment from air, land and water. Finally, the Snake River, ID, beset
by a cycling interaction of sediments, nutrients and low flows has many conflicting stressors
and human demands. The purpose for the following panel discussions is to explore how
ecological risk assessments help to evaluate and increase our understanding of the
complexities of these problems and provide the basis for better watershed management.
The U.S. Environmental Protection Agency (EPA) is placing increased emphasis on achieving
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integrated ecosystem protection. The Office of Water is working to meet Agency goals
through the development of watershed protection programs. This shift in emphasis is based
on a recognition that despite major advancements in environmental protection, and significant
observable improvements, degradation of ecological resources continues. More integrated
assessments of ecological resources at risk in watersheds are needed to solve remaining
problems.
Background
Under the Clean Water Act and Clear Air Act, implementation of best available technology and
establishment of criteria and permit limits continues to reduce direct discharge of pollutants
into surface waters and air. Implementation of regulations under FIFRA, TSCA and CERCLA
controlling land application and clean up of toxics is reducing soil, ground water and surface
water pollution. The outcome of these and other programs has been a resurgence of aquatic
life in surface waters, increased productivity of wildlife, and a significant increase in human
quality of life. However, despite decreasing pollution and improved environmental protection,
ecological degradation continues. Surface waters supporting aquatic life contain communities
with lowered diversity, non-native species and in many cases advisories restricting human
consumption of resident fish. Reproductive success of many birds and mammals is decreasing
and extinction of species within all classes of organisms, except humans, is increasing. This
degradation can be attributed to many factors including physical loss of habitat, reproductive
defects from bioaccumulative chemicals, human misuse of surface and ground water, and the
introduction of non-native species. Such human induced changes are some of the stressors
recognized as degrading ecosystems. Often the cause of degradation is not known. Past
program success in reducing pollutants in water, land and air through media specific programs
has served to highlight the diversity of continuing environmental problems.
To meet the challenge of a changing environmental focus, a process to understand and predict
ecosystem vulnerability to many stressors is needed. This process must take into account
the combined and cumulative effects of chemical, physical and biological stressors, the
dynamic relationships of biotic communities interacting with each other and their physical
environment, and the need to evaluate risk within a definable ecosystem, where stressors
from one medium, such as air, can transfer to others like water or soil. Assessment tools are
now available, and others are under development to evaluate the effects of specific stressors.
However, we need to use these tools in more integrated and innovative ways.
Developing a New Process
To incorporate multiple assessment tools and evaluate risk at an ecosystem level, an approach
may be derived from current ecological risk assessment methodology. Ecological risk
assessments have been used extensively by the Agency in a variety of applications (e.g.,
aquatic life water quality criteria, pesticide registrations, Superfund clean up levels). In 1992
the Risk Assessment Forum published the Framework for Ecological Risk Assessment (USEPA,
1992) to promote consistency in Agency use when addressing single chemical or physical
stressors. Ecological risk assessments contain three primary components: problem
formulation, analysis (both characteristics of exposure and ecological effects) and risk
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Water Criteria and Standards for the 21st Century
characterization. These three components are being expanded into a scientific process, based
on experimental design, to assess risk from multiple stressors impacting watershed
ecosystems. The process will directly support watershed management initiatives.
To develop the process, a multi-agency Technical Panel, co-sponsored by the Office of Water
and Risk Assessment Forum, was established in 1993 to develop case study examples of how
to conduct ecological risk assessments for watershed ecosystems. Watershed ecosystems
were selected to represent a landscape scale because watersheds are natural geographic and
hydrologic boundaries where the effects of diverse stressors in water, on land and in the air
combine in surface and ground water as it flows through the watershed. In addition, federal,
state and local organizations are already working to manage regulatory and non-regulatory
activities within watersheds to meet environmental goals. The case studies will provide
examples of the process and complexity of geographic risk assessments and form the basis
for guidance on how to conduct risk assessments for watershed ecosystems. Two principal
objectives were identified for this program: develop guidance on conducting watershed level
ecological risk assessments based on the scientific method, and using risk assessment results
to improve watershed management.
Based on initial objectives, coupled with what has been learned during case study
development, several significant conclusions have been reached. First, although watershed
management activities are well under way by many states and local organizations, the current
process used to define what human activities are responsible for observed degradation, what
degradation is actually occurring, and how best to reduce the risk from ongoing or planned
human induced changes is as varied as the number of projects. Dependence on best
professional judgement is central to the development of these efforts. Yet, best professional
judgement is difficult to evaluate because much of the information processing and decision-
making is in the mind of the professional making the judgement and less subject to review or
understanding by others. Best professional judgement will continue to be a key and essential
element of any watershed assessment. However, ecological risk assessments founded on the
principles of the scientific method require a search for alternative hypotheses and predictions,
add analytical rigor, and focus the principles of experimental design on evaluating the
combined and cumulative effects of multiple stressors on ecological resources of concern.
Application of the traditional scientific method is essential for development of watershed
ecological risk assessments.
A second important difference in watershed risk assessments is the primary focus on
assessment endpoints, and the degree of involvement of local, state and federal managers in
selecting them. Management input about watershed ecological goals and the translation of
these goals into assessment endpoints by risk assessors, provide the driving force for the risk
assessment. Instead of asking what organisms are likely to be impacted by a particular
stressor, more typical of traditional risk assessments, the question becomes which stressors
are likely to impact the ecological resource of concern. This shift in emphasis results in
significant changes in how the risk assessment team evaluates information and structures the
risk assessment. It also promotes an evaluation of the combined and cumulative risk of
exposure to multiple stressors based on a rigorous analytical design.
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Case Study Examples
The watershed ecological risk assessment case studies each provide an opportunity to
evaluate the value added when choosing to conduct an ecological risk assessment. Each of
these watersheds is already managed, and has been for some time. Each is subject to a
significant variety of human induced stressors that range from chemical contamination (e.g.,
Superfund sites, agricultural run-off or point-source dischargers), and physical alterations
(wetlands loss, dredging, sedimentation and erosion), to biological impacts (e.g., algal growth,
domesticated animals, introduced non-native species). Each watershed was selected in part
because significant information was already available on the watershed. In each case the risk
assessment has provided new ways of evaluating available information and new ways of
looking at the problems. A few of these are briefly described below; for additional discussion
refer to summaries of the break-out sessions in Session 3.
Endangered species are protected under the Endangered Species Act and of significant
concern to resource managers. The Clinch River Valley in Virginia contains among the most
diverse endemic communities of mussels in the country. Many of these mussel species are
now endangered. Local managers are working hard to protect mussel habitat to save these
species, but the effort has not achieved what was hoped for. In some areas, older mussels
are still alive but no young are being successfully reproduced. One of the significant
outcomes of the ongoing risk assessment of the Clinch River is the increasing consideration
of other possible causes for the decline, including the simultaneous change in the fish
community in the river. Since many endangered mussel species young must attach to a
particular species of host fish during a critical life stage, the loss of the fish host in the
community will result in the continued failure of mussels to recruit young. To save the
mussels it may be necessary to develop more effective management of the fish.
The Big Darby Creek in Ohio is a relatively unimpaired ecosystem based on aquatic community
measures and habitat structure. However areas of impairment can be identified along
different reaches of the stream. The purpose of the first phase of this risk assessment is to
evaluate the relationships among different land use activities, their proximity to the stream and
the observed differences in the biotic communities. In the second phase, a more detailed
evaluation of land use stressors will be conducted to evaluate what kinds of changes are most
likely to be causing adverse effects. Each land use is a complex of stressors that must be
evaluated. The Big Darby Partners, a local management organization, want to use the results
of the risk assessment to refine their current planning efforts.
The Middle Platte River in Nebraska is a exceptionally valuable natural resource that supports
major agricultural production, serves as the primary feeding and resting area for the
internationally important migratory bird central flyway, and supports a significant diversity of
resident birds, amphibians and fish. Historically described as a mile wide and an inch deep,
the river's character has changed significantly over the years because of increasing demands
for water, both within and upriver of the Middle Platte. Although highly managed, the
hydrology of the system is unique and not easily understood. The risk assessment process,
which included going to the watershed to talk with local managers and the public, has helped
identify conflicting interpretations of the river's hydrology. This, and the importance of the
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Water Criteria and Standards for the 21st Century
river's diminishing wetlands, prompted the risk assessment team to focus one aspect of the
risk assessment on more systematically evaluating the natural and human managed hydrology
of the river and its relationship to habitat needs for selected biota. This information will
hopefully aid resource managers in achieving consensus on an effective management plan for
the river to protect ecological resources and sustain agriculture and industry.
Waquoit Bay Estuary on Cape Cod in Massachusetts has been the focus of intensive research
on nutrient cycling for several years because of observed problems caused by over-
enrichment. Despite this effort relatively little data are yet available on the actual ecological
effects that over-enrichment is having on the bay. Nor is much known about the condition
of the freshwater component of the watershed. Researchers are still grappling with the
relative contribution of different sources of nutrients to the system. The risk assessment in
this case will more closely associate the nutrient inputs from the three primary sources (septic
systems, fertilizers, air deposition) to observable ecological effects on the eel grass
community most at risk in the estuary. In addition, the risk assessment will include
evaluations of the freshwater component. Finally, the risk assessment will recommend further
research in the bay, freshwater ponds and streams to more fully characterize the ecology of
the system and risk from stressors.
The Middle Snake River in Idaho is highly degraded from agricultural return flows, fish
hatcheries and dams. Sedimentation, over-enrichment, impoundment and water withdrawals
are taking their toll on native species, river flow and human enjoyment of the river. The risk
assessment in this case is focused on understanding the inter-relationships among water flow,
nutrients and sediments. They each impact the other and managing one without managing
all is problematic. The risk assessment will help to clarify these relationships, information of
value to managers trying to determine how best to meet human needs and aquatic life goals.
These brief descriptions highlight a few of the issues being addressed in the watersheds, and
a few of the approaches being used by the risk management and assessment teams
developing the case studies. Our first steps in developing these case studies have been
difficult. Traditional approaches to ecological risk assessment were not as effective for
watersheds. The risk assessors had to refocus on management goals and assessment
endpoints to make progress. As we develop analysis plans, more rigorous experimental
design must be applied. Throughout, the learning process has been rich and characterized by
new understanding of the power of applying the scientific method to problems of
understanding and managing risk.
U.S. Environmental Protection Agency (1992) Framework for Ecological Risk Assessment
EPA/630/R-92/001.
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Water Criteria and Standards for the 21st Century
ECOSYSTEM ANALYSIS FOR BIODIVERSITY CONSERVATION: SOME
PERSPECTIVES FROM THE NATURE CONSERVANCY
Brian D. Richter
Biohydrology Team Leader
The Nature Conservancy
Boulder, CO
Background
During the past few years. The Nature Conservancy (TNC) has taken a headlong plunge into
the morass of "ecosystem management." As with many other land managing organizations,
the Conservancy had come to understand that the management of isolated, fragmented
preserve areas for conservation purposes simply could not succeed when our management
influence was constrained within our own property boundaries. Through our experience in
managing a network of more than 1500 preserves across the U.S., we could well appreciate
the challenges of conserving biodiversity within a landscape matrix of diverse land uses,
watershed processes, species migrations and gene flows. While senior managers within the
organization were boasting of being a quiet, "science-driven" conservation organization, our
scientists were quietly driving the organization into ecosystem management.
Fortunately, we had a history of critical thinking about applied conservation biology, a lot of
biological management success and failure, and even a few scientists familiar with the
concepts of risk assessment to guide our early forays into ecosystem management. So when
the Conservancy decided four years ago to launch a fundraising campaign to fuel the initiation
of more than 70 individual ecosystem management projects (called "bioreserves").
Conservancy scientists felt reasonably confident that they could "walk the talk." As more
than 70 Conservancy planning teams simultaneously dove into strategic planning for their
respective ecosystem projects, they all worked within a planning and analysis structure we
call "The Six S's: Systems, Stresses, Sources, Situation (e.g., economic, social factors).
Strategies, and Success."
The first three of these S's represent an analytical process quite similar to the "problem
formulation phase" of the ecological risk assessment framework, as articulated by EPA
(1992). Using the Six S's, Conservancy planning teams first identify the ecological systems
of interest or concern, then evaluate the leading stresses and sources of stress to those
systems. As in ecological risk assessment, these analyses are based upon conceptual
ecological models of the systems to be protected.
The Six S's framework has had an immeasurably beneficial influence on the Conservancy.
For the first time. Conservancy managers and scientists are being recognized and rewarded
for sharing their knowledge about how ecosystems work, and for investing resources in
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planning their conservation activities strategically (based upon ecosystem knowledge).
Bioreserve strategic plans are based upon current, local, interdisciplinary knowledge of current
and past human activities within targeted watershed areas. This knowledge is used to assess
what is stressing the system and the biological implications of those stresses. Although this
planning process is quite time-consuming, few of the Conservancy's planning teams dispute
the merits (and necessity) of adding this level of rigor to decisions involving considerable
investment of organizational resources. The ability of such conceptual discussion and analysis
to improve our conservation effectiveness is now well established within our organization.
What Else Can Ecological Risk Assessment Do For Us?
While the Six S's planning framework has elevated the Conservancy's strategic planning
standards, these analyses of ecosystem stresses are generally based upon qualitative
information and intuitive reasoning. A common realization derived from these planning
exercises is that large holes exist in our understanding of present and historical conditions and
functions in our targeted ecosystems. For many of us, the idea of committing millions of
dollars and years of our time to conservation actions founded upon a weak knowledge base
and tentative hypotheses about the causes of ecosystem stress is terribly unsettling. At the
same time, many others within the organization are openly nervous about investing resources
in research activities that hold no guarantee of substantially influencing our decisions about
how to conserve biodiversity.
The scientific rigor embodied in the "analysis phase" of EPA's ecological risk assessment
process (EPA 1992) holds great promise for minimizing these conflicts between science and
applied management concerns within our organization. The ecological risk assessment
framework outlines a methodology for strategically engaging scientific methods in the
resolution of real world, applied ecosystem conservation issues. If the application of
ecological risk assessment principles can reduce the risk of investing in poorly designed and
directed research and lead us to better identification of the causes of ecosystem stress, we
expect that it will be quickly adopted within our organizational culture.
Challenges for Watershed Analysis
During the past couple of years, the Conservancy has begun to make some careful but
increasing investments in applied ecosystem research. The purposes of this applied research
closely parallel the intentions of the analysis phase of ecological risk assessment, as outlined
in the EPA framework document (EPA 1992): i) to characterize ecosystem stresses in time
and space; and ii) to characterize biological responses to these stresses (ecological effects).
While this analytical strategy appears conceptually sound, its application to watersheds and
hydrologic stresses is proving to be quite challenging. We would like to briefly summarize
some of the challenges we have identified in some of our early investigations of watershed
stresses.
Hydrologic regimes clearly play a preeminent role in structuring ecosystem conditions,
processes and functions within watersheds. The rates and timing of water flows over the
land surface, through ground water systems, and within channels directly shapes aquatic
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Water Criteria and Standards for the 21st Century
habitat conditions such as water depths and velocities, and indirectly influences water
temperatures and chemistry. Hydrologic regimes dictate the degree of connectivity between
floodplain habitats (such as backwater lakes and sloughs) and primary river channels, thus
influencing exchanges of nutrients and other materials between these habitats and controlling
access to floodplain habitats for feeding, resting, and reproduction by aquatic organisms.
Hydrologic regimes structure wetland or riparian environments by affecting flood inundation,
drought stress, and other critical environmental conditions that affect the distributions of
plants and animals in these ecosystems.
Although many of these hydrologically-driven ecosystem processes and functions are
intuitively understood by ecologists, four constraints are substantially limiting our abilities to
adequately characterize hydrologic stresses in time and space:
1. Existing hydrologic data collection networks and technologies are grossly inadequate.
The data needed to adequately assess hydrologic changes over time are available for
only a finite number of monitoring stations. Watershed analysts are commonly
constrained by the limited transferability of these data to their study areas, and the
limited utility of these data for calibrating simulation models. Stated simply, we need
more data.
2. Statistical summaries of hydrologic data (prepared by data collection agencies) are
generally limited to a handful of summary statistics such as monthly means. These
statistics are quite useful to planners and engineers concerned with human water
supply and flood protection, but most of the commonly published statistics are
meaningless to ecologists trying to evaluate ecosystem relationships. New
computational tools capable of more fully characterizing such hydrologic phenomena
as the magnitude and duration of flood and drought pulses, the timing of extreme
water conditions, and the rate of change in hydrologic conditions are needed to
support ecosystem analysis.
3. Hydrologic data generally needs to be translated into associated habitat characteristics
(such as flow velocities or depths, or duration of inundation) before it can be used in
ecosystem analyses. Few scientists are familiar with the tools hydrologists use (such
as hydraulics models) to perform such translations. Therefore, ecologists need to be
able to ask hydrologists for assistance in characterizing hydrologic stresses in the
language of ecologists.
4. Hydrologic processes alter physical habitats over time. The hydrologic variation (such
as water table or river fluctuations) that influences ecosystem functions and biotic
distributions operates within the physical structure of the environment (i.e., the river
channel, floodplain, wetland pond, etc). When the physical structure of the
environment changes, the distribution of habitat characteristics such as flow velocities
and depths may change substantially as well.
The degree of physical habitat change important to ecological components such as fish
(e.g., changes in the relative abundance of riffles and pools) may be relatively
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inconsequential to other components such as a riparian forest. Therefore, we need to
understand the nature and rates of geomorphic change occurring within the
ecosystems we are studying, we need to assess its significance to the ecological
components we are analyzing, and we need models capable of simulating these effects
over time.
Beyond these challenges in characterizing hydrologically influenced habitats and stresses in
space and time, we are also challenged in our attempts to link such stresses to changes in
ecosystem biota. Within the Conservancy, we have assembled a team of hydrologists and
ecologists to advance our understanding of the role of hydrologic regimes in biological
systems (which we call "biohydrology"). Through involvement in research efforts across the
country, the biohydrology team is beginning to recognize some common pitfalls in our
attempts to link hydrologic regimes to biotic changes over time.
Many of the problems just described for characterizing hydrologic stresses are equally
pertinent to biohydrologic analysis. We seldom have adequate data on historical distributions
and abundances of native species and communities. It's difficult to identify the specific
hydrologic characteristics that might best explain changes in the ecological component of
interest, due to the limited availability of information about life history strategies and
hydrologic dependencies. Changes in ecological patterns have to be characterized at spatial
and temporal scales compatible with hydrologic characterization.
If all the hurdles mentioned previously in this paper could be overcome, we will still be
hindered by the absence of a general theoretical framework for linking hydrologic and biotic
change at various spatial and temporal scales, and the lack of successful research designs for
other researchers to emulate. To build such a general framework for biohydrologic analysis,
an extensive review of currently available data collection technologies and networks for
monitoring both current and past hydrologic and ecologic conditions needs to be undertaken.
Ecologists specializing in research design at different levels of biological organization (e.g.,
populations, communities, ecosystems) need to collaborate with hydrologists and fluvial
geomorphologists to seek common intersections between data, processes, and life histories.
Opportunities for making substantial contributions to the emerging field of biohydrology are
clearly abundant.
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Water Criteria and Standards for the 21st Century
SELECTING WHAT TO PROTECT IN THE WATERSHED ECOSYSTEM:
USING MULTIPLE ASSESSMENT ENDPOINTS FOR THE MIDDLE PLATTE
RIVER SYSTEM
William Whitney
Director, Prairie Plains Resource Institute
Aurora, NE
and
Donna Sefton
U.S. EPA
Washington, DC
The Middle Platte River watershed is situated at the crossroads of North America, where a
major east-west human transportation route intersects the north-south Central Flyway avian
.migration corridor. The watershed is an internationally important system that supports rich
agricultural production, provides habitat for over 300 species of migratory birds (including six
threatened or endangered species), and supports a wide variety of multiple uses, including
recreation, irrigation, agricultural and industrial water supply, hydropower generation, fish and
wildlife habitat, and groundwater recharge. The Middle Platte and its alluvial aquifer also
provide drinking water, support irrigated agriculture and other industries, serve as a focal point
for community and economic development and sustain remaining fish and wildlife habitat
within the basin.
The watershed covers approximately 5,130 square miles in south-central Nebraska. It
includes broad, braided river channels and associated wetlands and uplands. Most water flow
in the watershed comes from snow melt and runoff from precipitation. The flows in the Platte
River are naturally highly dynamic with intermittent high and low flows and flooding.
Diversions of surface water for irrigation and power generation have a major effect on the
natural rhythm of Platte River flows in the sub-basin.
To successfully manage these diverse resources and uses in a complex system like the Middle
Platte, education of stakeholders, from children to adults, is essential. An understanding of
the important resources such as the storehouse of biodiversity in wet meadows, native prairie
and backwaters is needed. Key ecological relationships must be studied. These values must
be balanced with the multiple uses of associated resources.
To develop the watershed ecological risk assessment for the Middle Platte, a cooperative team
of local, state and federal professionals initiated the development of a watershed ecological
risk assessment based on three cornerstones: problem identification, stakeholder involvement
and comprehensive integrated action. Learning about the watershed and getting stakeholders
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involved has been central to the process. Activities included tours of the watershed, a Platte
Basin Ecosystem Symposium and public meetings to obtain feedback on what is of value to
people living in the watershed which support quality of life, diversity and economic stability.
These were followed by focus group meetings with commercial groups (farmers, irrigators,
utilities), environmental interests, and state and local governments. Based on feedback from
stakeholders, and current scientific understanding of local resources, a general management
goal was identified by the group that focuses on maintaining a functioning and sustainable
watershed ecosystem that includes habitat components, landscape patterns and valued
species, while maintaining economic stability.
These general goals provided the basis for the work group to select a diverse set of
assessment endpoints to consider for the risk assessment. Assessment endpoints should be
characterized by three things: ecological significance, susceptibility to a stressor, and societal
value. Based on background work, the group selected sets of assessment endpoints. These
include a habitat component with three habitats: wet meadows, sandbars, and backwater.
Biota selected included representatives from migratory birds, nesting birds, amphibians and
native fish. Potential interactions of these endpoints will also be considered.
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Water Criteria and Standards for the 21st Century
MANAGING CONFLICTING USES IN THE MIDDLE SNAKE RIVER
KEVIN J. BEATON
Deputy Attorney General, Environmental Affairs
Idaho Office of Attorney General
Boise, ID
The Snake River is a major river in Idaho that serves as the life blood of the agricultural
economy. The Snake begins in the Tetons. By the time water reaches the Middle Snake, it
has been impounded many times. The Middle Snake is considered a separate river because
at Milner Dam, water from the river is completely appropriated for agriculture where it enters
irrigation canals. Sometimes there is no flow below the dam. Water re-enters the river
channel by natural springs.
These changes make the Middle Snake the most degraded portion of the river. Degradation
is caused by a combination of excess sediments and nutrients, and hydrological modification.
Flow restrictions caused by impoundments from hydroelectric facilities, and withdrawal of
water for irrigation are major contributors to problems associated with nutrients and
sediments. The Middle Snake provides ample evidence of what is wrong with the Clean
Water Act. The Act does not address hydrological modification, non-point sources
discharges, habitat destruction, or nutrients.
Sources of stress include nutrient loading from irrigation run-off. Numerous aquaculture and
fish hatcheries divert water from natural springs. Outflowing water is regulated under NPDES
permits for control of solids but not nutrients. Five hydroelectric facilities are in operation
below Milner Dam that provide Idaho regions with some of the cheapest electricity in the
country. These facilities contribute to sediment build-up, changes in water temperature and
habitat modification. These changes, coupled with several drought years have resulted in low
flows, high plant growth, rooted aquatic plants and algae, low dissolved oxygen, lowered
biotic diversity, and replacement of native species with stress tolerant species. Five molluscs
are now listed under the Endangered Species Act.
Public concern over changes in the river has resulted in the emergence of stakeholder groups
who are addressing the restoration of the river. A Nutrient Management State Planning
Group, composed of members from local governments, industries, citizen groups and state
and federal resource agencies are working toward better management of the river. The first
phase of the plan focuses on reduced loading of sediments and nutrients from best
management practices and point source controls. However, it is recognized that reducing
sediment and nutrient discharges is unlikely to meet management goals, and that more water
will be needed to scour and flush the river.
Water rights, however, have been in litigation for over 10 years and 150,000 claims have
been made during reviews of river water appropriations. Human induced changes to the
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hydrology of the river through efficient irrigation and ground water use have resulted in
decreasing natural spring flows over the last 30 years. The Endangered Species Act has, and
will continue to impact water flow issues and water quality. There are four endangered
species in the U.S. Fish and Wildlife reclamation plan. The Bureau of Reclamation has
released water from reservoirs at times to ease pressure on salmon populations. Thus,
conflicting uses in this watershed are more than a local issue. They result from national
policies as well. Settlers were encouraged to settle in the arid west and establish and
maintain agricultural production. Hydroelectric power development has been strongly
encouraged. These earlier goals and policies now conflict with current goals to protect
biological integrity of our nation's waters, including the protection of endangered and
threatened species.
The key to solving problems relating to these conflicting uses in the Middle Snake River is
quality science. Only through good science, that is accurate and accepted by the community,
can we restore state waters and move forward. The ecological risk assessment and nutrient
management plan are essential to this process.
GENERAL CONCLUSIONS FROM PARTICIPANT FEEDBACK:
• Watershed ecological risk assessments can be an effective process for using quality
science in a systematic way to reach consensus on, and prioritize environmental
problems.
• As a cooperative and educational process, risk assessment is valuable for managers,
industry, scientists and the public (stakeholders).
• Good communication, coordination and interest in achieving environmental goals
among stakeholders is essential for success. All must participate.
• When watershed stakeholders use quality science to agree on how to address
environmental problems, problems are more likely to be solved through voluntary
actions.
• Guidance on the development and use of watershed ecological risk assessments is
needed. Use of that guidance will depend on the availability of a facilitator to initiate
and promote the watershed ecological risk assessment.
• Watershed ecological risk assessment is an integrated and cooperative process to
evaluate environmental problems using quality science. The purpose is to promote
understanding among stakeholders so that better watershed management plans can
be devised using available tools. More information is needed concerning how risk
assessment will affect standards implementation.
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Session 3
Water Criteria and Standards for the 21st Century
SESSION 3 - PANEL DISCUSSIONS
PROTECTING ENDANGERED SPECIES
Endangered species are sentinels of the larger problem of ecosystem degradation. Protection
of a single species is not possible without protecting the ecosystem upon which it depends.
Participants in this session discussed how the goal of protecting endangered species may
improve through the use of watershed management based on ecological risk assessments.
The session was based in part on evaluating problems related to protecting endangered
mussels in the Clinch River, Virginia.
John E. Miller Panel Moderator
Environmental Scientist ' •
Office of Emergency and Remedial Response
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC
This panel was convened to discuss current problems and successes in protecting endangered
species and highlight the value of ecological risk assessment for improving management
decisions. The Clinch River watershed ecological risk assessment case study is featured as
an illustration. Each panelist provided an overview of their program and highlighted the value
of science and risk assessment in improving endangered species management.
Bill Kittrell
Clinch Valley Bioreserve Manager
The Nature Conservancy
Abington, VA
The purpose of management by The Nature Conservancy is to protect species before impacts
occur so that impacts can be avoided, and to protect resources at risk. The Clinch Valley
Project began in 1985 when the Nature Conservancy purchased Pendleton Island in the Clinch
River and jumped into watershed level protection, focusing on a richly diverse but threatened
aquatic community. Watershed management focused on protecting mussel habitat because
habitat degradation and loss was considered the greatest threat to this group. Participation
in the watershed ecological risk assessment led to a better recognition of the need to integrate
management of the fish and mussel communities because these mussels are obligate
parasites on fish for a short period during their life cycle.
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Session 3
Jack Edmundson
Branch Chief, Environmental Analysis and Documentation
U.S. Department of Agriculture
Hyattsvllle, MD
The USDA does not have an environmental mission, but recognizes that they have a role in
protecting endangered species. USDA is working to increase awareness of environmental
issues and is dedicated to complying with the Endangered Species Act and other
environmental laws. The USDA follows an ecological risk assessment process that includes
a biological assessment where hazard characterization, exposure assessment and risk
characterization are completed. These biological assessments are used in the consultation
process with the U.S. Fish and Wildlife Service. Greatest success occurs when USFWS and
USDA work one on one together, the biggest problems come from difficulties in coordination
between the Agencies and having the necessary diversity of experts. To improve the process,
we need better information transfer including a central database.
THE FISH AND WILDLIFE SERVICE'S ROLL IN PROTECTING
ENDANGERED SPECIES
Ren Lohoefener, Ph.D.
Chief, Recovery and Consultation Branch
Division of Endangered Spcies
U.S. Fish and Wildlife Service
Arlington, VA
The purpose of the Endangered Species Act (ESA) is to provide a means to conserve and
protect threatened and endangered species. Currently there are 875 species listed nationally,
60% are endangered, 40% threatened. Of these 53% are plants and 47% are animals.
Twenty-five percent are freshwater dependent. In the 1992 Report to Congress, 40% are
listed as stable and improving, 60% are listed as declining or unknown. There are 200
additional species considered candidates for listing and another 3700 species are potential
candidates but there is insufficient information. ESA Sections 4, 5, 6, 9 and 10 provide
authority to USFWS to list and recover species, acquire land, cooperate with states and local
governments, enforce the law and provide permits for taking of species. Section 7 specifically
requires interagency cooperation and an evaluation of the impacts of federal action.
Determination of impact and effects on endangered species functions as an assessment of risk
for specific species.
The U.S. Fish and Wildlife Service (Service), along with the National Marine Fisheries Service,
is responsible for implementing the Endangered Species Act of 1973, as amended. The
Service's role in recovery of threatened and endangered species has many facets.
• The Service initiates, participates in, and supports programs designed to
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Session 3 Water Criteria and Standards for the 21st Century
"recover" species before they decline to a point that federal listing as a
threatened of endangered species is necessary. Examples of programs include
the Partners in Flight and Partners in Wildlife initiate. Also, the Fish and Wildlife
Refuge system includes over 470 nits and 91 million acres. About 25% of
federally protected species are known to occur on refuge lands.
• Section 4 of the Endangered Species Act (Act), gives the Service the authority
to list species as threatened or endangered, currently, nearly 900 species of
plants and animals in the United States and territories have been listed.
• Cooperation between and among the states, territories, and the Service is
authorized by Section 6 of the Act. All states and territories have cooperative
agreements for animal species and all but a few have cooperative agreements
for plants.
• Interagency cooperation is the subject of Section 7. All federal agencies are
mandated to use their authorities to carry out programs for the conservation of
threatened and endangered species [Section 7(a)(1)]. Section 7(a)(2) requires
Federal agencies to insure that any action they fund, authorize, or carry out has
a "is not likely to jeopardize" effect on federally listed species and does not
destroy or adversely modify critical habitat for listed species. For action that
"may affect" listed species or critical habitat. Federal agencies are required to
consult with the Service or the National Marine Fisheries Service, depending on
which agency has lead for the listed species.
• The prohibitions on "take" of listed plant and animal species are specified in
Section 9. The Act defines take as "to harass, harm, pursue, hunt, shoot,
wound, kill, trap, capture, or collect, or to attempt to engage in any such
conduct." The Service's Division of Law Enforcement has authority to protect
federally listed species.
• Through the procedures outlined in Section 10, private individuals and non-
federal agencies can acquire permits that allow the take of federally listed
species and their habitats as long as that take is incidental to otherwise lawful
activities. The procedure is often referred to as Habitat Conservation Planning.
• Finally, the Service is responsible for monitoring species for five years after
they have been recovered to ensure their status does not begin to decline.
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Water Criteria and Standards for the 21st Century
PROTECTING ENDANGERED SPECIES
Janet McKegg -
Director, Natural Heritage Program
Maryland Department of Natural Resources
Annapolis, MD
Maryland's Nongame and Endangered Species Conservation Act establishes the Department
of Natural Resources as the agency responsible for the identification and protection of
threatened and endangered species in Maryland. The Maryland Natural Heritage Program is
the Department's lead for implementation of the Act. As with the Federal Endangered Species
Act, Maryland's Act authorizes the listing of species that are threatened with extinction within
the State and sets out prohibitions to prevent their extinction. One of these prohibitions
allows the Department to include conditions for the protection of listed species in State-issued
permits, projects that use State funds, and projects that are proposed by State departments
and agencies.
The Maryland Endangered Species Act provides some fundamental tools for the protection of
listed species, such as a mandate to conserve listed species. Without this authority, the State
could take no action to identify or protect these species. However, the prohibitions and
restrictions contained in the Act can be considered as primarily stopgap actions, such as
inserting conditions in permits, until recovery plans can be developed for a particular species.
Because few funds are available for developing of comprehensive recovery plans for listed
species, this type of temporary protection, gained through environmental review, may be the
only type of protection that many listed species receive. Over the long term, the cost of
providing protection through environmental review can be high, but the results can often be
poor.
The Program's most successful approach to maintaining endangered species is to conduct
research into the distribution, life history and habitat needs of the species and then develop
a protection and management strategy based on the needs of the species. Although the initial
costs of this approach can be high, the results are long-lasting.
EPA Framework for Ecological Risk Assessment (February 1992) defines ecological risk
assessment (ERA) as a "a process that evaluates the likelihood that adverse ecological effects
may occur or are occurring as a result of exposure to one or more stressors." The process
described in the above paragraph as the Program's most successful approach to maintaining
endangered species is essentially an informal, intuitive, simplified seat-of-the pants ERA where
threats identified are used to guide protection and management actions. When the
maintenance of an endangered species population is among the assessment endpoints for an
ERA, then the risk characterization would identify threats to that population and lead to the
development of options to maintain the population. Therefore, ERA appears to have a great
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Session 3
potential to contribute to the protection of endangered species. EPA could adopt a policy that
one of the sets of data to be obtained for any ERA is the presence of known locations of
listed species in the project area. This would be a major step towards making ERA a
significant tool for endangered species protection.
MAJOR ISSUES AND RECOMMENDATIONS FROM DISCUSSION:
• Communication and coordination among multiple agencies are essential for successful
implementation of the Endangered Species Act. This must include working to
understand the mission and responsibilities of each of the agencies and their role in
protecting species. •
• To really protect endangered species an ecosystem approach is necessary. Individual
species cannot be managed and protected without protecting the ecosystem upon
which the species depends. Conducting careful scientific evaluations of life history
characteristics, community structure, habitat requirements of species, and evaluating
potential stressors impacting ecological resources within watershed to determine risk,
provides a mechanism to meet this need.
• A process for protecting endangered species should be accessible to all levels of
government, especially the local level where management is normally implemented.
Local organizations expressed interest in investment by state and federal agencies in
providing support for implementation.
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Session 3
Water Criteria and Standards for the 21st Century
SESSION 3 - Questions and Answers
Q: Wants to discuss water quality standards program and how it relates to protection of
Endangered Species (ES). (OK Resource Board)
A: Working with EPA and State to look at WQC and standards and whether they protect
ES, in conjunction with Section 7 process. Working on MOU with EPA and
consultations. (Lohoefener)
A: Do not have good criteria on listed species. Need to develop surrogate species that
will measure the impacts for these species that cannot be measured. (Miller)
Q: When will MOU be signed? What will be role of the states? (Virginia)
A: Working hard on MOU and is close to signing. FWS intends to work closely with
states. Policy statement coming down from Secretary of Interior. (FWS)
Q: What can be done legislatively other than ESA USDA does not know of any farm bills?
(Inside EPA)
A: See Ed. Note
Q: How can local government get involved in protection of ES? Local governments need
more information. (MD local government)
A: Incorporate into five year plans and other planning documents where endangered
species are located. Avoid these areas and develop guidance to help local government.
(NO
A: Heritage Foundation is getting GIS system to help local governments determine where
species are to help in planning and zoning decisions
A: FWS has developed work group for getting outreach during development of recovery
plans.
A: Need bilateral feedback during watershed protection projects from local government,
states up to Feds and feds back to local governments. (Miller)
Q: Doesn't think we can develop criteria that will guarantee protection - cautions against
jeopardizing threatened and endangered species. Only...a certain level of proof that
we should be held to. Implementation of ESA on states that we not jeopardize the
species (EPA Region 4)
A: Thinks its a good goal but will be hard to do.
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Session 3
Q: As program grows up, where will resources come from to solve the problems? Is there
a coherent strategy on how to implement (watershed-based)? How will we implement
to see actual accomplishments? (MA)
A: Recommend recovery plans to consider all species in the area. There are ways to
allocate resources so higher efficiency where areas with many species may be
prioritized. Develop guidance to encourage concentrating on areas where the species
have similar life histories. (NC)
A: Work with best scientific data available, failing that, err on side of the species. We are
going toward watershed/ecosystem approach and will not be looking at just single
species but many in the same area. (FWS)
Q: Doesn't see why we are considering endangered species more sensitive than other
species that are protected by criteria. Thinks we should assume that standards we are
developing are protective of endangered species. If not, then they should be
considered during standards development process. Any comments by FWS or EPA on
whether the criteria are protective, have they been considered? (NC)
A: We don't have a vehicle to address endangered species separately from other species.
(FWS)
A: Criteria documentation says they are 95% protective of all species. Is it a gamble, do
the endangered species fall into that 5%? Doesn't think it is necessarily so. (EPA)
A: Afternoon sessions will address these issues (Dave Sabock)
Q: What I am hearing is that ESA is not as powerful a tool as I thought. If a species is
listed in the area will a criteria be reviewed to see if it is protective of the endangered
species?
A: Most likely outcome from discussions between EPA and FWS are recommendations
from the parties involved to reassess uses and criteria when endangered species are
involved in a particular area. Development of a site-specific criteria. Not authority of
FWS to determine if the criteria are protective or not of an endangered species.
However, FWS may make recommendations to change uses or standards of an area.
(Dave Sabock)
Q: Dam halted in Tennessee due in part to endangered species in area. Group of people
have been relocating the mussels. Is relocation a good idea to protect species? (TN)
A: Not FWS's first choice to relocate, but sometimes it may be a reasonable and prudent
choice. (FWS)
A: Doesn't think it is a viable alternative because of survival problems (Nature
Conversancy)
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Session 3
A:
Water Criteria and Standards for the 21st Century
Jeopardy opinion was that if they could, would support efforts to recover these
mollusks (J. Christian)
A: We don't know enough about species to relocate these species. Has not worked in
many instances. Must have unoccupied habitat. (Jan)
Q: Important to look at whole, don't often recognize what the problems are without
looking at whole. How do you see evaluation of ecosystem as a mechanism to better
protect species? (Marcy)
A: FWS approach is not a new one, but gets big and resource intensive. Good
philosophy, but may be hard to measure results in short time frames.
A: For first time, we are taking conservation seriously by using this approach. Critical
that information be disseminated at the local level. (Nature Convervancy)
[Ed. .Note: The purpose of these proceedings is to provide a written compendium of the
presentations and discussions as soon after the conference as possible. It is being published
even though answers to some of the questions are not available. Persons interested in the
answer to this question are encouraged to continue discussions with the appropriate sources.]
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Water Criteria and Standards for the 21st Century
PROTECTION THROUGH IMPROVED LAND USE PLANNING
Human land use directly changes the characteristics of the landscape and effects ecological
resources within watersheds where changes are occurring. Participants in this session
discussed issues surrounding the management of land use, the types of measures needed to
understand ecological processes affected by different land use, and how ecological risk
assessments can help provide direction for land use planners. Land use planning in the Big
Darby Creek, Ohio was featured.
Susan M. Cormier, Ph.D. Co-Moderator
Ecological Monitoring Research Division
Environmental Monitoring Systems Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Marc A. Smith Co-Moderator
Environmental Supervisor
Ecological Assessment Section
Division of Surface Water
Ohio Environmental Protection Agency
Columbus, Ohio
In order to learn better ways to scientifically predict environmental risk, an ecological risk
assessment was undertaken in the Big Darby Creek watershed. The Big Darby Creek
watershed is a freshwater, stream ecosystem in central Ohio. The watershed is a high quality
ecosystem which is still relatively free of pollution problems. However, this exceptional
stream is threatened by an assortment of stresses originating with day-to-day activities of
people in the watershed. Some of the key stressors include sedimentation, nutrient
enrichment, changes in hydrology and geomorphology, loss of a riparian zone and chemical
contamination. Approximately 90% of land use is agricultural, but there is increased
residential development in the eastern portion of the watershed near Columbus, Ohio.
The ecological risk assessment has identified land use as a critical element for relating
watershed scale processes to ecological effects. The case study has elected to characterize
the system by correlating land use with biological effects at the ecoregional scale for
agricultural, forested, residential and industrial land uses. These data will then be used to
forecast changes to the biological communities in the mainstem and tributaries of the Big
Darby Creek Watershed. Some specific management concerns will be examined including
presence of riparian zones, residential density and storm water control. The risk assessment
will then become a tool to generate the information needed for sound decision-making by
county commissioners and engineers, by township trustees and other local officials, and by
voters. The processes and analytical methods used to develop the risk assessment will
provide a concrete example of how an ecological risk assessment might be done in other
ecosystems.
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Session 3
INCORPORATING ECOLOGICAL CONCEPTS AND BIOLOGICAL CRITERIA
IN ECOLOGICAL RISK AND WATERSHED MANAGEMENT
Chris O. Yoder
Manager, Ecological Assessment Section
Division of Surface Water
Ohio Environmental Protection Agency
Columbus, Ohio
Current strategies for the assessment and management of ecological risk, while allowing for
the incorporation of ecological information, are largely dependent on non-ecological measures
and principles. Water quality program managers, being hampered by a lack of adequate
funding and mandates to produce evidence of environmental improvements quickly, have
historically relied on surrogate indicators such as administrative actions (e.g., permits issued,
funding awards, legal actions) and relatively simple physical/chemical indicators of aquatic
ecosystem integrity. Recent developments and refinements of reliable biological measures
have enhanced our ability to produce comprehensive and ecologically relevant expressions of
aquatic ecosystem integrity. The availability of these measures and tools close an important
gap in our ability to successfully manage water resources both locally and on a watershed
scale.
The condition and well-being of aquatic resources is the combined result of chemical, physical,
and biological processes as reflected in Clean Water Act goal statements (e.g., maintenance
and restoration of biological integrity). To be truly successful in meeting these goals via an
ecological risk approach to watershed management, monitoring and assessment tools which
portray and integrate the interacting chemical, physical, and biological processes and the
integrated result of those processes are needed. This condition is reflected directly by
biological criteria which are numerical and narrative expressions that describe the reference
condition of a waterbody of a given use classification (i.e., designated use). This is especially
relevant to watershed level assessments because many of the effects at this level are a direct
result of the interaction of multiple chemical, physical, and biological factors. Impaired aquatic
ecosystems lack integrity and thus show evidence of departures from the reference condition
which is embodied by the biological criteria.
Many logic ecosystems are seriously impaired nationwide, an indication that existing
frameworks for water resource protection and watershed management have achieved only
partial success. Aquatic faunas, particularly those impacted by watershed level such as land
use changes, wetlands degradation, habitat degradation, riparian encroachment, excessive
sedimentation, and nutrient enrichment, continue to decline despite our current national
efforts in pollution control. Biological criteria offer the type of evaluation framework that is
needed to more effectively target ecological risk and watershed management efforts, better
define management goals, and more accurately measure program effectiveness. A landscape
partitioning framework such as ecoregions is also required to account for natural landscape
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Water Criteria and Standards for the 21st Century
variability. This variability can frustrate uniform and overly simplified approaches to
watershed management.
There are a number of areas of watershed management in which biological criteria and
assessment methods can and do play a key role. As a criterion for determining use
impairments biocriteria have played a central role in the Ohio Water Resource Inventory (305b
report), Nonpoint Source Assessment, and watershed specific assessments. As an
environmental end-point, biological criteria represent a goal for watershed management
efforts. However, biological assessments must also be accompanied by appropriate
chemical/physical measures, land use, and source information necessary to establish linkages
between the watershed use activities and instream responses. Utilizing this type of
environmental feedback loop makes sense given the spatial and temporal uncertainties
involved with assessing and controlling varied point and nonpoint source impacts on a
watershed scale.
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Water Criteria and Standards for the 21st Century
CHALLENGES IN DEVELOPING ENVIRONMENTAL INDICATORS TO
ASSESS THE CUMULATIVE IMPACT OF WATERSHED DEVELOPMENT
Thomas R. Schueler
Executive Director.
Center For Watershed Protection
Silver Spring, MD
Many communities across the country have become interested in the use of environmental
indicators to assess the individual and/or cumulative impact of watershed development on
streams. Environmental indicators are a broad series of biological measures and responses
that can often integrate the numerous impacts produced by urban storm water. Although
they have yet to be systematically applied to urban watersheds, the results so far indicate that
stream biodiversity sharply declines even with modest increments of development. Several
case studies on the application of environmental indicators will be presented from around the
U.S.
Environmental indicators are a more attractive alternative to traditional regulatory tools, such
as end-of-pipe discharge limits. Since they integrate the effects of land use, they have the
potential to become a credible and defensible planning and zoning tool. To achieve this
potential, however, several technical and programmatic challenges must be surmounted.
These include the problems of scale, resolution, standardization, benchmarks and confounding
sources. Each of these methodological problems will be critically analyzed, and some
uggested watershed protocols for the use of environmental indicators will be presented.
LAND USE PLANNING AT WATERSHED SCALE TO REDUCE
ECOLOGICAL RISK: CONFLICTS BETWEEN NATIONAL AND LOCAL
CONTROLS
Steven I. Gordon, Ph.D.
Department of City and Regional Planning
Ohio State University
Columbus, OH
Ecological risk assessment at the watershed scale seeks to establish the relationships between
changes in land use and the potential increases in risk for the survival of our valuable aquatic
resources. Recent studies in the Big Darby Creek Basin near Columbus, Ohio demonstrate
that local planning and zoning approaches will not reduce the overall risk of environmental
degradation and may in fact exacerbate the level of damage. Coordinated regional strategies
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Session 3
aimed at controlling land use, providing for regional storm water control facility construction
and maintenance, and continuing monitoring of the impacts on stream quality and flow appear
to be the preferred method for avoiding these problems. Yet, the control over land use
decisions, storm water drainage, and related facilities management lies mainly with local
municipalities that have strong political incentives to maintain that local control.
Past attempts at regional planning have met with strong resistance and have mostly resulted
in failure. If the current focus on ecological risk assessment is to be successful, new,
compromise approaches to coordinated local and regional land use management that are
acceptable to local communities will need to be found.
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Water Criteria and Standards for the 21st Century
SALAMANDERS IN SUBURBIA: MEETING THE CHALLENGES OF
CRITICAL RESOURCE PRESERVATION WHILE MAINTAINING PRIVATE
PROPERTY RIGHTS
Christine R. Furr
Land Use Planner
Christine Furr Consulting
Dublin, Ohio
Critical resource preservation goals are often made at the macro-level, while implementation
is most likely to be effective at the micro-level whereby individual properties are affected. The
connection between the goals and the avenues for implementation are often incomplete.
Land use decisions are influenced by market forces, given shape to some extent by local land
use plans, then ultimately modified by locally-applicable subdivision and zoning regulations.
Land with a variety of aesthetically attractive features (such as rolling meadows, waterways
and woods) is often sought by residential developers and home buyers; however, the same
features are already home to functioning, sensitive ecosystems which are of significant value
as local, regional and national resources.
Land use planning is a first vital step toward translation of critical resource preservation goals
into policies in a given jurisdiction. Land use plans must be supported with appropriate
subdivision and zoning regulations for implementation of the higher critical resource
preservation goals (upon which plans are based). And, further, the role of strong private
property rights in a given jurisdiction does not necessarily serve to weaken or invalidate critical
resource goals as implemented through subdivision and zoning.
A PRACTICAL MORALITY FOR CONSERVATION AT THE WATERSHED
LEVEL
Alan Randall, Ph.D.
Professor
Department of Agricultural Economics
Ohio State University
Columbus, Ohio
The moral foundations are surprisingly robust of a conservation policy decision rule based on
benefits and costs, but subject to a safe minimum standard (SMS) of conservation. The
benefit cost rule provides an account of the net contribution of policy to the satisfaction of
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Session 3
human preferences. The SMS constraint provides direct protection of ecosystems for their
own sakes, or humans seek prudently to avoid the risks entailed in ecosystem destruction.
Nevertheless, commitment to a SMS policy is unlikely to be iron-clad. Moral reasoning might
find circumstances in which the sacrifice that would ensure conservation is too much to ask
of particular groups of people. Practical reasoning suggests that people asked to bear an
enormous cost in order to keep a conservation commitment may well defect. These
considerations suggest some general principles for designing a workable conservation policy.
First, the objective should focus on the sustainability of ecosystems rather than the
preservation of particular species. Second, in order to maintain the commitment to
conservation, the costs imposed on any particular group of people must be kept tolerably low.
Costs tend to be high, for last-ditch preservation efforts made in a crisis atmosphere: so,
early warning and early implementation of conservation strategies makes sense. Local
conservation efforts sometimes impose high costs within a watershed in order to provide
benefits for society at large; in such case, compensation mechanisms are both equitable and
effective in facilitating local cooperation.
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A PRACTICAL MORALITY FOR
CONSERVATION
Alan Randall
The Ohio State
University
1. Maximize (Benefits-Costs), but subject
to a Safe Minimum Standard of
conservation
• Why B-C?
• Why SMS?
2. But commitment to SMS is less than
iron-clad.
• Moral reasons
• Practical reasons
-------
Resources
available,
t+1
Regeneration Fr
lower bound
45-degree
line
Trim
SMS Resources
available, t
3. SMS: the SMS of Preservation
Cmin: Mimimum Necessary
Consumption
SMS: the SMS of Conservation
-------
Resources
available,
t+1
Regeneration Fn
x^ lower bound
SMS SMS
45-degree
line
Resources
available, t
4. The Conservation Dilemma
The best hope is to avoid it by
maintaining SMS.
-------
5. Policy Conclusions
Sustain Ecosystems
Early Warning
Compensation, Cost-sharing
Those who seek conservation have a strong
interest in keeping its costs tolerably low.
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Session 3
Water Criteria and Standards for the 21st Century
MAJOR ISSUES AND RECOMMENDATIONS FROM DISCUSSION:
• Land use planning is a political process and reflects how a community wants to change
over time. Little consideration is given to impacts outside of the local community.
How can watershed planning take place when most planning is local? There is a major
communication disconnect among local planning groups and state and federal
environmental programs. Data from governmental entities is under used by planners.
• Recommend encouraging community officials to identify critical resources such as
wetlands, stream buffers and others and to work toward sustaining an ecosystem.
Ecosystem protection is more cost effective and ecologically viable than focusing on
preserving an individual endangered species.
• The question was raised about the level of controls that are acceptable before society
will be begin to reject further work to protect the environment.
• States cannot meet restoration goals with current regulations. Alternative approaches
for controlling nutrients, habitat alteration, sediment, and non-point source degradation
are needed at the state level.
• To improve land use planning incentives are needed such as: cost sharing for land use
planning and data collection, pooling resources for land use planning, and allow
flexibility in reporting on other programs when using a comprehensive planning and
implementation system. Efforts are needed to counteract the tendency to use private
property rights as a basis for degrading resources.
• Better science is needed to help define environmental conditions, the effects of
multiples stressors, evaluating exposure and identifying and evaluating response
indicators.
• When dealing with environmental management it is important to avoid the lose of gains
made in environmental restoration because of an abrupt change in management to
address other stressors. Good integrated planning is necessary based on an
understanding of the ecological resources of concern.
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SESSION 3 - Questions and Answers
Q: How do you define Regions in Ohio?
They are ecoregions.
What is role of biocriteria to address land use problems?
A:
Q:
A:
Identify impaired areas.
Identify sources of impairment.
Q: Can audience recommend how land use planning can be incorporated into EPA's
initiative?
A: One example where failure to plan has thwarted ESA habitat conservation, failure of
land use planning to address habitat of species. FWS tries to encourage planning for
habitat protection, provides list compiled from various state sources to the states of
species under pressure.
Q: Most planners don't know about list data. Planners at local level who are not getting
information from state.
A: An example of a success story involves a Michigan condominium developer plan. The
Nature Conservancy provided developer with information of species which developer
incorporated into project to protect species.
Q: How do you prioritize sources of stress? Do you rank value of resources?
A: Use GIS - layer topography to identify sensitive areas under greatest pressure by
mapping
critical resources (rivers and floodplains)
roads and other structures
areas under development pressure (areas purchased by developer)
Develop special policies for critical areas that are under development pressure
Q: How well do communities adhere to zoning rules? Historically zoning exists until
developer shows up with a proposal.
A: Ground swell of public pressure to stick to zoning plans.
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Water Criteria and Standards for the 21st Century
COMPETING DEMANDS FOR WATER
Donna F. Sefton
U.S. EPA
Region 7
Kansas City, MO
Moderator
Water is an essential resource for all living things. It is also essential for agriculture, industry
and other human endeavors. The removal of water from natural watersheds to support
increasing human populations and economic development is changing watershed ecosystems.
This panel explored how competing demands for water simultaneously impacts natural
ecosystems and human interests in sometimes unexpected ways. Participants discussed
water management problems in the Middle Platte River watershed and evaluated the value of
ecological risk assessment may have in developing management plans for more balanced and
effective water use.
The Middle Platte River watershed in Nebraska is part of the larger Platte River watershed that
extends into Colorado and Wyoming. There are controversial issues surrounding water use
in the watershed. Questions addressed by the panel included: what are the water issues in
the Platte, and how might we use a systematic scientific approach to better solve theses
issues? Panelists also provided background on their role in the watershed.
RECOGNIZING LOCAL CONCERNS WHILE DOING RISK ASSESSMENT AT
WATERSHED LEVEL
Richard Anderbery
Water Quality Coordinator
Tri-basin Natural Resources District
Holdrege, NE
The boundaries for Natural Resource Districts in Nebraska are based on watersheds. As a
result, the state has been using a watershed approach to manage their natural resources since
1969. Primary concerns in the watershed involve establishing an effective balance between
irrigation demands and sufficient water for wildlife. Water quality issues focus on ground
water nutrient levels. Activities by the NRD include working with farmers to increase
irrigation efficiency.
Abstract: I have been involved in the Risk Assessment Study of the Middle Platte river since
the study began in September of 1993. Having lived in the Platte Valley all my life, I am very
much aware of the changes that have taken.place on the Platte River. The river is an
extremely complex system. The result of this study could have a positive effect on the Platte
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River providing that the proper information is provided in doing this study. The river has a
direct effect on the economy of the area because of its many uses and needs. Some factors
involved in this Risk Assessment are Upland Game Habitat, Central Flyway for migrating birds,
HydroElectricity, Surface Water Irrigation, Groundwater Irrigation, Recreation, and Agriculture
to name just a few.
The Middle Platte River is unique in that it is a very wide flat river with intermittent flows
feeding it. This is the reason for the changes that have taken place on the Platte and one
reason for the need for local input in doing a Risk Assessment. The hydrology of the river is
very complex as a result of storage facilities, surface and groundwater irrigation, migrating
birds, flows, and wetlands all having a direct effect on each other. It is very difficult to
understand or do a Risk Assessment Study if you have not seen the river.
Local districts have adopted and enforced many new management practices that have created
a positive effect on river water quality and quantity.
The results of a Risk Assessment Study on the Platte River could have a positive effect on
future management provided proper and complete information is used in doing this study. The
river is a very complex system and management decisions will have a direct effect on the
economy of the area because of its many uses and needs. Factors involved in doing this
study are Upland Game Habitat, Habitat for Migrating Birds, Hydro Electricity, Surfacewater
Irrigation, Groundwater Irrigation, Recreation and Agriculture to name just a few.
The Platte River is unique in that it is a wide flat river and does not have definite banks along
most of the river. Because its basic source of water is from mountain snow melt, historically
the river had high flows in the spring of the year and was often dry in the summer. Storage
structures and return flows have evened the flows, however, they are still intermittent in
portions of the river. Hydrologic changes in the river have a direct effect on all aspects of the
ecology and economy of the river. Excessive changes in management practices could create
a negative result rather than a positive result because all aspects of the ecology are dependent
on each other. For example some proposed minimum flows, in the river could deplete water
available for crop irrigation, thus reducing a source of food for migrating waterfowl and upland
game.
Forestation along tie Platte River has increased since storage facilities have been installed
creating more even flows and less flood flows. This has improved habitat for upland game
such as eagles, deer, pheasants, rabbits, and songbirds; however, this is not considered ideal
habitat for migrating birds which are increasing in numbers in the Central Flyway. We must
develop a balance in this area-
Quality of groundwater and surfacewater is an important factor in the ecology of the river
basin. Natural Resource Districts are the governmental agencies responsible for water quality
in Nebraska. They are addressing this through local regulations that are adopted according
to the level of contamination. This is important as the problem is usually localized and it is
not necessary or practical to develop regulations on a state or federal level. Pollution can vary
even within a county and therefore regulations should be developed according to need. The
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Water Criteria and Standards for the 21st Century
education process should be used to eliminate further contamination. Local people are very
receptive to this because their livelihood depends on the quality of this water and they are
willing to protect it.
Irrigation water use efficiency has taken tremendous strides over the past years as irrigators
and irrigation districts became aware of the need to better utilize the water that is available.
Improved compacted canal systems, underground delivery pipe, and modern automatic
controls are just a few of the irrigation district's improvements. Irrigators have changed from
open ditches to gated pipe and from surfacewater to pivot irrigation. They have also adopted
the use of flow meters and surge valves and are using irrigation scheduling. These practices
not only reduce water usage, but in return could have a negative effect on return flows to the
river, groundwater recharge and wetlands.
To do a risk assessment study of the Platte River that can be used by managers we must
study the watershed as a whole and strive to create a balance in management
recommendations. The work group must be acquainted with the structure, hydrology, and
complexity of the river. This is the reason that local input and involvement is critical in
developing a balanced risk assessment study. The socioeconomic impact could be
tremendous if it is weighted too far in either direction.
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Water Criteria and Standards for the 21st Century
Jeremiah Maher
Relicensing Coordiator
Central Nebraska Public Power & Irrigation District
Holdrege, NE
The Central Nebraska Public Power-and Irrigation District operates a multi-use project that
handles irrigation, and storage water in Lake McConihay for additional irrigation. There are
four hydroelectric plants. In addition the District is responsible for addressing ground water
recharge, and protection of wildlife habitat and recreational opportunities. Objective
information is central to successful balancing of these potentially competing needs for limited
water supplies. Work has been ongoing since 1984; primary focus has been on possible
effects to endangered species. Work on the ecological risk assessment will augment this
effort. However it is essential that the risk assessment process be an objective assessment
of scientific data and provide an effective means of educating the public. The assessment
should not focus on values that are not based on science. In addition the sciences of
economics and sociology should be included. This will help avoid the creation of a "designer"
watershed which is a conception about what the watershed should be.
John Bender
Water Quality Coordinator
Nebraska Department of Environmental Quality
Lincoln, NE
The Nebraska Department of Environmental Quality administers all aspects of the Clean Water
Act except Section 404. Most recent 319 programs and point source programs are evolving
toward watershed management. The NPDES permitting process is being modified for
watershed planning where permits are issued within a watershed at the same time. The main
role of DEQ is to formalize procedures to get data on the table for management decisions.
However the DEQ does not make decisions concerning water quantity.
SELECTING WHAT TO PROTECT IN THE WATERSHED ECOSYSTEM:
USING MULTIPLE ASSESSMENT ENDPOINTS IN THE MIDDLE PLATTE
RIVER SYSTEM
William Whitney
Prairie Plains Resource Institute
Aurora, NE
The Objective of the Middle Platte ERA is to provide decision-makers, i.e., people involved
with various watershed resource aspects and regulatoy procedures, with a tool to assist them
in seeing beyond parochial concerns to a basin-wide prspective. With information on
ecological risks associated with potential land and aater management o ptions within a basin,
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it is our hope that decisions can achieve more balance among varied objectives. It is vital to
realize that ecological risk assessment is a fluid process relying on communication among
many people with many perspectives and an ever-changing body of iinformation. The
process, however, can reveal a concrete framework of ecological relationships and factual
information acceptable to all stakeholders. Subsequently, on this framework can grow a
broad-based understanding of what alternate management strategies might do or what kinds
of research information is needed.
The Middle Platte is an extremely complex system. The challenge in developing a risk analysis
for the basin is to: 1) Identify ecosystem components along with assessment and
measurement endpoints, 2) rate assessment endpoints as to susceptibility, societal value, and
ecological relevance, and 3) correlate changes in land use and hydrology (the Platte may be
unique i regard to the ecological and economic importance of both surface and underground
water) with changes in species and ecological community structure. Historic trends in
stressors and effects have been developed to serve as the basis for predicting the effects of
a range of potential management alternatives within the basin.
A focus on the landscape habitat mosaic derives from a general hypothesis that there is a
critical mix of habitat to support both the natural biodiversity and the economy of the basin.
The task is to identify the optimum structure and then evaluate management strategies in light
of their ability to establish that structure. Risks associated with a particular strategy are
measures of how far its endpoints deviate from the optimum structure.
Paul J. Currier
Deputy Director, Platte River
Whooping Crane Trust
Grand Island, NE
The primary emphasis of the Platte River Whooping Crane Trust is managing critical habitats
on the Middle Platte River. Management plans focus on maintaining the system as an
integrated unit that will support habitats for insects, clams, and invertebrates as well as
migratory birds. Wet meadows, woodlands, brush areas and the main river channel are
managed. Management techniques include grazing, controlled fire, restoration and creation
of wetlands, cutting trees to provide resting places for cranes, restoration of sand islands and
elevated points on the islands used for nesting, and grassland restoration. We are trying to
manage resources in a highly developed watershed system with only a small natural area
remaining. Water is the basis of the system we are trying to restore. Understanding the
dynamics of the system are central to our efforts.
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Water Criteria and Standards for the 21st Century
ISSUES AND RECOMMENDATIONS FROM DISCUSSION:
• Public involvement is essential for successful management of limited water supplies.
The strength of the watershed ecological risk assessment is the opportunity for group
synergism and dialogue among organizations that are often at opposite ends of the
issue. The group process helps to diffuse polarization.
• Risk assessment is a scientific process that provides a forum for focusing on issues
and ideas in a systematic way and allows diverse groups to reach a common
understanding. It also promotes education.
• Ecological risk assessment provides a scientific basis for targeting management
options.
• The risk assessment provides a framework for looking at the landscape mosaic as a
large scale and dynamic system. This will help to identify a range of quality
management options.
• EPA can serve as a facilitator in the risk assessment process. The ecological risk
assessment will bring a scientifically based approach to issues to reduce political and
emotional discord.
SESSION 3 - Questions and Answers
Q: How would more systematic scientific evaluation help resolve competing water
demand issues? (Sefton)
A: There have been a lot of overflow problems. Mistakes were made in terms of habitat
protection at the start of the project. Further information may not help, but people
must get together and use risk assessment process to solve problems. (Richard
Anderberry)
A: Most of the information from our watershed management experiences in management
end up in scientific documents, etc. Risk assessment will involve a lot of people that
otherwise would not be involved and expose them to this information. We provide a
lot of public education. (Paul Currier)
Q: About $45 million will be available for irrigation. How will risk assessment be used to
allocate these resources?
$45 million was the figure used in the revised EIS. Is it economically feasible for
hydroelectric producer, who is a wholesaler, to provide this amount of money? This
process will bring to light what the priorities are, and the amount of money needed to
address the problems. (Jay Maher)
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Q: How will the $45 million be used?
A: As it is planned new, about $39 million will be used for habitat restoration and $6
million for loss power revenue. (Jay Maher)
FWS has identified certain areas they want to see restored and that is what the
majority of the $39 million will be used for. (Paul Currier)
Q: Is the $45 million from the state of Nebraska?
A: No 80% is from Central Public Power, 20% from Nebraska Public Power (Jay Maher}
Q: In earlier Sessions, one work group identified 3 or 4 biota that should be focused on.
Was this helpful or have we left out endpoints that should be included?
A: All issues identified are important but several key ones were left out - such as
economic and other human issues. (Jay Maher)
A: Process may focus too much on the science, even though the science is important.
Conceptualizing the system as a whole and deciding what areas to focus the scientific
studies on is an enormous task. (William Whitney)
Q: Increasing Flow regimes is discussed in the EIS, are we going to see ecological benefits
from the extra flow?
A: If the $45 million is appropriated amount used the individual rate would only be
$3/year. We don't think the proposed goes far enough. Modification in our proposal
would maintain recreation uses, irrigation uses and provide some increase flow during
low flow seasons. We are not talking about a dramatic effect on the flow of the river,
however. (Paul Currier)
A: Let me point out that Central Power can not pass on rate to individuals. Companies
we sell our electricity may, and if this is acceptable to the State of Nebraska, then
we'll agree, but $45 million is too much for our company to deal with. We will see,
however, an incremental increase in flow from our management practices (Jay Maher)
Q: How much of an issue of water quality is involved here?
A: Hasn't been much of an issue to date. A recent issue has been a concern over
temperature increases caused by the plant, but it only affects a very short distance of
the stream (Jay Maher)
A: Overall the Central Platte River gives partial support for aquatic life. When this study
was made the focus was on aquatic life and not other wildlife. There are problems in
the on overall watershed ecology. Ecological response assessment can help us set
goals and prioritize issues. (John Bender)
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A:
Water Criteria and Standards for the 21st Century
We do have high pesticide discharges that we don't yet understand; however, USGS
is beginning studies (Paul Currier)
Q: Please elaborate on the Districts' Nutrient Management Plan.
_A: This is to address groundwater problems. Our ground water management plans
require:
farmers must take deep soil samples (3 feet)
check water for nitrogen
consider nitrogen levels when applying nitrogen
This has been in effect 3 years. Central Platte ground water management has been
active for 5 years and has seen a decrease in nitrogen. (Richard)
Q: Given new emphasis on ecological assessment, how are we going to resolve the
Federal/State stakeholder friction?
A: EPA is coming down on the state trying to say that 401 certification should include
flow regime. We can't because we have state laws that don't let us. (John)
A: Ecological risk assessment will bring a scientific based approach to issues and
hopefully cut down on some of the political and emotional heat. (Sefton, EPA)
Q: What is the role of Department of Water Resources? (Susan, EPA)
A: They are the water accountants for the State of Nebraska. They track how much
water each person has a right to. (John)
Q: Is the Department of Water Resources on the risk team?
A: They have been asked but have not been actively participating on the team. They
have, however, attended some public meetings. (Sefton, EPA)
Summary: Risk assessment is tool to connect stakeholders, provide scientific analysis of
data, and identify data gaps. (Sefton, EPA)
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MANAGING OVER-ENRICHMENT FROM AIR, LAND, AND WATER
Over-enrichment of the nation's waters from point source discharges, septic systems, air
deposition, agricultural practices, gardening and other sources presents a difficult problem for
those trying to manage watersheds. Nutrients present scientific as well as management
challenges. Participants in this panel discussed how scientific advancements can be used in
the context of ecological risk assessment to help risk managers develop better plans to control
over-enrichment.
NUTRIENT ENRICHMENT OF WAQUOIT BAY, MASSACHUSETTS
Maggie A. Geist Co-Moderator
Research Translator
Waquoit Bay National Estuarine Research Reserve
Waquoit, MA
Waquoit Bay is a shallow, poorly flushed embayment on the south coast of Cape Cod. Its
watershed covers 23-square miles of diverse habitats including barrier beaches, dunes,
marshes, and uplands. In the Waquoit Bay watershed, valued resources are at risk from a
suite of biological, physical, and chemical stressors that have accompanied the approximately
fifteen-fold increase in population in the past 50 years.
The waters of Waquoit Bay show signs of degradation primarily due to nutrient loading.
Ecological effects include loss of eelgrass habitat, a valued resource, and their replacement
with mats of opportunistic macroalgal species, and concomitant changes in the vertebrate and
invertebrate communities that utilize eelgrass beds. A proliferation of docks and excessive
boating use are other human activities that may add suspended solids and toxics to the Bay,
compounding the effects of other stressors. Additional chemical impacts in the watershed
are connected with the Massachusetts Military Reservation (MMR) which has been declared
a Superfund site by the EPA. MMR activities contribute phosphorus and possibly other
contaminants to nearby freshwater ponds. In addition, herring runs and trout streams that
feed into the Bay are under potential stress from development which will add nutrients and
may alter flow rates.
The Waquoit Bay National Estuarine Research Reserve is cooperating with the U.S.
Environmental Protection Agency in an ecological risk assessment case study. This study will
aid the Reserve in examining and evaluating multiple ecological effects from anthropogenic
stressors in the watershed, with the goal of helping risk managers make informed coastal
policy decisions.
Among the stressors, a most pervasive agent of change is the increased nutrient loading to
the Bay, associated with changing land use patterns. Research has identified subwatersheds
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of Waquoit Bay that have experienced different rates of development and have different rates
of nitrogen-loading. Studies show that the primary producers in the receiving waters of the
subwatersheds reflect these differences. Several models, which differ in assumptions and
parameters, have been developed to calculate nitrogen loads to receiving waters in coastal
watersheds underlain by glacial soils. Some model parameters are sources of nitrogen (septic
systems, fertilizers, atmospheric deposition, run-off), transport of nitrogen through the
terrestrial and aquatic components of the system, losses of nitrogen through dispersion,
dilution, denitrification, the size of the watershed, the number of residents and residences, the
distance to the receiving water body, the size of the receiving body of water, and the flushing
rate of the receiving body.
As part of the ecological risk assessment, model outputs will be compared and analyzed and
attempts made to establish minimum and maximum contributions from major nitrogen
sources. The models will be used in conjunction with land use data to calculate past, present
and future loading of nitrogen and to relate that nutrient load to changes in the abundance and
distribution of eelgrass, an indicator of estuarine health. This information may help coastal
planners target a nitrogen loading limit for Waquoit Bay.
NITROGEN TMALs FOR BUZZARDS BAY EMBAYMENTS
Joseph E. Costa Co-Moderator
Director
Buzzards Bay Project
Marion, MA
The Buzzards Bay Project, a participant in the U.S. Environmental Protection Agency's
National Estuarine Program, developed a strategy to manage anthropogenic nitrogen sources
to protect and restore water quality and living resources in Buzzards Bay. The recommended
nitrogen management strategy focuses on implementation on land use and sewage
management controls which are based on annual nitrogen mass loads estimated from land use
evaluations. The mass loading approach (as opposed to a water quality standard) was
deemed the most defensible management strategy based on existing scientific knowledge, and
was also the strategy most likely to be successfully implemented.
\
In the recommended approach. Total Maximum Annual Loads (TMALs) for nitrogen impacted
embayments are established based on historical trends in water quality and estimates of
historic inputs of nitrogen based on land use. For unimpacted embayments, or impacted areas
where historical data is lacking, a tiered system of TMAL limits was established that could be
applied to any embayment of known size and hydraulic flushing. This tiered system was
based on the best available scientific information from experimental mesocosm manipulations
and ecosystem studies where nitrogen loadings were estimated and ecosystem response
documented. Since it is meaningful to characterize nitrogen loading rates as either annual
loadings per unit area or loadings per unit volume during the water turnover time, both
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Water Criteria and Standards for the 21st Century
methods were used to establish nitrogen loading limits. Turnover time, using a "Vollenweider
model" flushing coefficient like that used for setting phosphorus limits to lakes, is used to
establish the nitrogen loading limits.
Recommended nitrogen TMAL limits are tiered to reflect existing water quality management
classifications as well as bathymetric and hydrographic features of the embayment. The
tiered system enables different ecosystem endpoints to be targeted based on existing
embayment conditions and uses. Managers and local officials can choose a water quality goal
for an embayment by changing its water quality designation (i.e., by defining what degree of
environmental degradation is acceptable in that embayment}. Once the essential data about
embayment hydrology, and existing and potential future watershed loadings are evaluated,
this approach establishes an objective process for federal, state and local authorities to
manage nitrogen inputs from both point and non-point sources in coastal embayments.
The response of coastal ecosystems to nitrogen loading is complex and poses a challenge to
the ecological risk assessment approach. To evaluate the appropriateness of its recommended
limits, the Buzzards Bay Project is currently evaluating the relationship between nitrogen
loading and embayment water quality and living resources through its Citizen's Water Quality
Monitoring Program.
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VALUE OF WETLAND TRANSITION ZONES IN PROTECTING THE
NUTRIENT BALANCE OF COASTAL WATERSHED ECOSYSTEMS:
TALAMANCA-CARIBBEAN BIOLOGICAL CORRIDOR, COSTA RICA
Jennie Myers
Consultant to The Nature Conservancy
Latin America-Caribbean Division
Cambridge, MA
Background
The coral reefs, lagoons, and wetlands of Costa Rica's Talamanca region link the Gandoca/
Manzanillo National Wildlife Refuge with Cahuita National Park to the north, and form the
lowland and marine component of the bi-national La Amistad Biosphere Reserve, a World
Heritage Site included in the Nature Conservancy's Last Great Places initiative. Together,
these areas contain more than 60 percent of Costa Rica's biodiversity, and are further linked
ecologically with Panama's San San N.W.R. to the south and to critical coastal habitats along
the Nicaraguan border to the north.
Along the rapidly-developing Talamanca coast, important aquatic habitats considered
vulnerable to eutrophication are currently subject to a variety of transition zone
disturbances—artificial drainage of flood plain soils, land clearing and sedimentation—that both
enhance nutrient inputs and affect crucial nutrient transformation (buffering) processes in the
soil. Soils of wetlands, floodplains, and similarly affected areas have been shown to intercept
nutrients in groundwater and surface flows, affecting ecosystem nutrient availability and
exerting significant control over aquatic plant community structure and secondary
productivity. On a landscape scale, these functions dampen ecosystem shifts that have been
shown to occur in nutrient-limited systems at very low thresholds of watershed development.
Of the highly-ranked elements of biodiversity tracked in The Nature Conservancy's databanks,
approximately one third are found in wetland, riparian and aquatic environments, many of
which are nutrient-limited. This project seeks to characterize nutrient flows, to examine how
key buffering processes are affected by land use alteration, and to develop simple soil-based
indices and bio-monitoring measures that integrate several elements of ecological risk in both
pristine and degraded systems.
While the research and management effort underway in Talamanca was not structured as an
ecological risk assessment, it may serve to illustrate some opportunities for adapting aspects
of a risk assessment paradigm to nutrient management in tropical watersheds. Because
landscape functions are known to exhibit spatial and temporal patterns that are distinct from
those of temperature zones, principles of ecological risk assessment may prove valuable in
ordering future assumptions to develop,a timely, if qualitative understanding of ecosystem
relationships, focusing education and planning efforts, refining rapid ecological assessments.
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Water Criteria and Standards for the 21st Century
capitalizing upon strengths of spatial analysis, designing cost-effective monitoring regimes,
etc.
Objectives:
a)
b)
c)
d)
Characterize nutrient transformation processes that occur in soils of
representative transition zones between terrestrial environments and water
bodies;
Examine the effects of current deforestation, drainage, and other hydrologic
alterations on accepted indicators of transformation functions;
Recommend suitable bio-indicators and monitoring strategies to identify nutrient
enrichment trends and related turbidity shifts in receiving waters; and
Work with local partners to develop practical methods and predictive tools for
evaluating cumulative nutrient managementneeds, planning sound development
patterns, and setting management priorities that are effective in preserving and
restoring important transition zone functions.
Expected Products and Results
Part 1
1) Characterization of nutrient flow pathways affecting transition zone functions
of case study lagoons, fringe wetlands and streams
2) Data on the nutrient transformation potential of representative transition zone
soil classes under natural and disturbed conditions, with mappable factors
prepared in a format suitable for entry into GIS systems
Part 2
1) Tested bio-monitoring methods suitable for anticipating trends in nutrient
enrichment and evaluating ecosystem protection needs
2) Identification of easily recognizable patterns in macro-invertebrate behavior
which can be related to increased turbidity or nutrient availability associated
with basin land use change
3) Recommendations for the use of bio-indicators in ecological assessment
protocols for tropical streams and aquatic systems which can reveal shifts in
nutrient availability and/or turbidity.
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Pans
1) Nutrient loading assessment for representative coastal floodplain settings
2) Recommendations for protecting and restoring nutrient transformation functions
in study area transition zones
3) Basis for a standardized "rapid assessment method" to be used in predicting the
potential of different ecosystem components to function as buffer zones for
nutrients, and in evaluating the effects of alteration upon buffering functions
4) Recommendations for development patterns, densities and land management
practices needed to preserve and restore transition zone functions
5) Tested nutrient loading spreadsheets suitable for local use in objectively
quantifying development capacity and focusing land planning and management
efforts.
Collaborating Institutions
The Nature Conservancy; Univ. of Costa Rica/CIMAR; Institute of Ecosystem Studies; Woods
Hole Oceanographies Inst.; Univ. of New Hampshire Dept. of Water Resources; Univ. of
Georgia Inst. of Ecology; Watershed Management Institute; Local NGO staff.
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Richard Batiuk
Chesapeake Bay Program
U.S. EPA
The Chesapeake Bay is a large complex watershed encompassing 64,000 square miles. Two
key parameters were used to assess the condition of this large watershed: the decline of
dissolved oxygen since the 1950's, and the decline of bay grasses. These changes were
evaluated relative to levels of suspended solids and nutrient loadings. Monitoring data and
models were used including a watershed model that connects land base and nitrogen
deposition to a hydrodynamic model and eutrophication model. Work is ongoing to include
feedbacks within the biological system to determine what will change as nutrients are
removed from the system. To develop the management plan, loads delivered by the Potomac
River were considered along with the Susquahanna, James, Rap/York, West Shore, East Shore
watersheds. Comparing loads from these subwatersheds helped determine the best nutrient
management decisions. The combined models provided the information needed to allocate
loadings and led to decisions that are cost effective.
ISSUES AND RECOMMENDATIONS FROM DISCUSSION:
• It is important to consider the relative significance of difference sources of nutrients
to determine how to manage watersheds most effectively. Sources include wet and
dry deposition as well as point and non-point discharges to water.
• There is a trade-off on different management options that must be considered.
Management options that replace septic systems with sewers help to reduce non-point
discharge of nutrients. At the same time, sewer systems support a much more
developed community that adds nutrients to the system in many ways.
• A eutrophic state index for estuaries is needed.
• More research on the contribution of nutrients from air deposition is needed. Agencies
need to address the interactions of different media when assessing risk.
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SESSION 3 - Questions and Answers
Q: Suzanne Marcy - Commented that risk assessment discussion good. How do we use
risk assessment to account for significant amount of load from air?
A: Richard Batiuk - Trend was from point source thinking to nonpoint source thinking and
now the trend is to wet fall and dry fall sources. Need to recognize all sources, how
they get there. Then what is most cost effective way to deal with issue. Is it easier
and more cost effective to get it out of air or get it out of other sources. First get
information, then back it up to source, then look at cost effectiveness and feasibility.
A: Joseph Costa - For Buzzards Bay load is 10-15% of total load from atmospheric
deposition. Total amount has not changed much over time. Makes sense to look at
significance of sources.
Q: Jeff Harvey - Idaho State Environmental Quality Agency. Has found dense
development on lake fronts overtime. As they go to ranchettes there are large changes
in phosphorus loading with minor changes in vegetation. If they sewer the areas to
get rid of septic load, then there is greater development
Q: Joel Salter - EPA HQ Recreational boating as a nutrient input?
A: Joe Costa - fecal coliform does increase but believes sediment resuspension most
significant source of nutrients as a result of recreational boating.
A: Maggie Geist - More concerned with boat props churning up sediment in shallow
embayment. Already a no-wake zone, but keels and props from boats go to
sediments.
Q: Suzanne Marcy - Want recommendation to EPA on needs in handling overenrichment.
A: Tom Brayman, NYC - Would like eutrophic state index for estuaries. Also want to
know where high nutrients go. When energy transfer goes to sediments then system
not functioning properly. Want scientific studies in this area to use for management
decisions.
A: Need more science for air component of evaluation. Need to bring agencies together
on interaction of media.
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CONFLICTING USES AND THEIR IMPACTS - HOW TO MANAGE THEM
Managers of many river watersheds must address diverse and seemingly conflicting uses of
the river, each of which has at least one and possibly many impacts. How do we determine
which, among the bewildering array of problems, are most important? How can private, local,
state and federal interests agree on a course of action? The Snake River watershed is a
textbook example of multiple, conflicting uses that have resulted in nutrient enrichment,
sedimentation, reduced flow, and loss of indigenous species. The panel used the Snake River
as a starting point for discussing how ecological risk assessments may provided the needed
interpretation for stakeholders to reconcile conflicting demands and protect their resource.
Pat Cirone Moderator
Environmental Services Division
U.S. EPA Region 10
Seattle, WA
The Snake River ecological risk assessment is focusing on only a limited stretch of the river
defined by hydroelectric dams. Primary problems in the Snake are linked to water use and
associated limits of available water. Multiple impoundments and heavy sediment and nutrient
loadings combine with low flows resulting in significant degradation.
THE MIDDLE SNAKE RIVER: ECOLOGICAL RISK ASSESSMENT AND
STRATEGIES FOR RECOVERY
Peter A. Bowler
Department of Ecology and Evolutionary Biology
University of California, Irvine
Irvine, CA
Abstract. Prior to disturbance, the Middle Snake River had a natural biology that was
extraordinary, including elements which were endemic, relict, anadromous, and more
widespread in distribution. Above Shoshdne Falls there was a distinctive "Upper Snake River"
fish fauna, which overlapped in only a few taxa with the "Middle Snake River" fauna of over
two dozen species below the natural barrier of Shoshone Falls. The fish fauna above the
barrier falls is now poorly represented between Milner Dam and Shoshone Falls, and only one
population of cutthroat trout has survived, and it is hybridized. Below the falls, the
anadromous taxa are eliminated and included the famous fall Chinook salmon stock for which
a tributary creek and river falls are named, a late spring or summer chinook stock, steelhead.
Pacific lamprey, and white sturgeon (the resident population is endangered). The mollusc
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fauna was also remarkable, and was characterized by a guild of coldwater, lotic taxa. These
coldwater taxa are now either extinct, endangered, or rapidly declining The present mollusc
fauna has shifted in species composition from that of a coldwater, free-flowing habitat to one
characteristic of warm, shallow, eutrophic lakes, with taxa being tolerant of moderately
eutrophic conditions gaining in presence. The exotic New Zealand mudsnail which was first
noted in the area in the mid-1980s is now the dominant mollusc, and there are five listed and
three candidate threatened or endangered species.
A history of unmitigated human impacts is responsible for this faunal transformation.
Complete dewatering of the river at the Milner Dam diversion during irrigation season and
upstream water storage eliminated spring runoff and natural annual flushing; at the same time
sediment from agricultural runoff and aquaculture outfalls which was rich in nutrients
accumulated, blanketing the benthos and thalweg. Dairies and feedlots, as well as local
towns, contributed waste to the system. Nearly all of the aquifer tributaries were developed
for aquaculture or diverted for agricultural or domestic use; rather than contributors of high
quality water, most are point source polluters from aquaculture and agricultural runoff. A
sequence of dams inundated riparian and lotic habitat, interrupted natural sediment regimes
an the natural hydroperiod, and also operated in a manner to track electric need (peak-loading)
which caused diurnal fluctuations in water levels, with severe impacts on the invertebrate
fauna in zone of daily wetting and drying. The benthos accumulated muddy, nutrient rich,
anoxic sediments while the littoral zone experienced sediment stripping or streambed
armoring. The reduction in the magnitude of peak-load operation recently has reduced all
scouring since spring runoff no longer occurs, and has resulted in colonization of shallow
riffles and rocky point-bars by riparian vegetation. There has been a shift from a diatom
sheath community in the shallow shoreline rocky habitats to one dominated by green algae
and macrophytes.
Potential contributors to the challenge of raising the ecologic condition of the area include
suction dredging of selected reaches to remove sediment and macrophytes, implementation
of Total Maximum Daily Loads (TMDLs) on a reach by reach basis, better control of sediment
in agricultural runoff, and a dovetailing of needed river operation measures with Federal
Energy Regulatory Commission (FERC) license requirements for hydroelectric facilities. There
have been many vertebrate and many invertebrate extinctions in this cultural sacrifice area,
but better stewardship and an improved quality of life for the environment and humans can
be hoped for if ecological risk assessment is taken seriously. Success should be measured
not only by meeting TMDL budgets or macrophyte and algal growth which inhibits human
recreational use of the river, put also by the survival and expansion of healthy, viable
populations of the lotic mollusk fauna, particularly those listed s Threatened or Endangered.
"Destroying or damaging a natural system is a reprehensible act. A badly damaged ecosystem
is highly visible evidence of misplaced values. It proclaims not only ethical insensitivity of the society
in which it occurs, but also poor management. After all, pollutants are merely misplaced resources.
Nutrients added to lakes, rivers, and oceans are badly needed on our agriculture."
John Cairns, Jr. (1982)
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Water Criteria and Standards for the 21st Century
The Natural Resources: An Historical Perspective
The Middle Snake River ecosystem, the reach between Milner Dam (River Km 1030.4) and
King Hill (River Km 880.7), comprises one of the most remarkable biologies of the state,
including the "Upper Snake River" fish fauna of fourteen native taxa above the 212 foot (64.6
m) Shoshone Falls and the "Middle Snake River" fauna below it, consisting of approximately
twenty four species though some of these are headwater species not occurring in this river
(Smith, 1978; Simpson and Wallace, 1978; Bowler, et al, 1992). There is little overlap in
species between these two discrete faunas, and the assemblage below Shoshone Falls
represents the maximum interior penetration of anadromous fishes and the Columbia River
elements. Among the over two dozen species native to Middle Snake River sub-basin are
many now extinct or endangered, including the fall chinook salmon, a late spring or summer
Chinook stock, steelhead, white sturgeon, and Pacific lamprey. The Shoshone sculpin (Cottus
greenei)\s restricted primarily to springs along the river and is one of Idaho's few endemic
fishes. Today it is a Candidate Endangered Species due to habitat loss. The red band trout
is now found a pure strain only in King Hill Creek, a tiny, isolated tributary. This area was
famous for its salmon fishery (Gilbert and Evermann, 1894; Murphey, Freeman and Bowler,
1993), as attested by names such as Lower Salmon Falls, Upper Salmon Falls, and Salmon
Falls Creek, and it was heavily used by native Americans for thousands of years.
The mollusc fauna is also unique, and includes 17 native and one exotic clam taxa, and 30
native and two introduced snail species, half a dozen of which are endemic relict species from
the later Pliocene (Blancan) Lake Idaho or subsequent Pleistocene Lakes (Frest and Bowler,
1992). Five snail species are listed as Threatened (Valvata utahensis. Bliss Rapids Snail
[Taylorconcha serpenticola, see Hershler, et al, 1994]) or Endangered (Pyrgulopsis idahoensis,
Banbury Lanx, Physa natricola) in the Middle Snake River,... there are three candidate
endangered species Fluminicola columbiana, Fisherola nuttalli, Anodonta californiensis, and
several of the declining lotic taxa are also becoming increasingly rare and should be candidates
Stagnico/a hinkleyi, for example. Prior to disturbance the reach_was characterized by a suite
of several dozen lotic, cold water, species. The largest mussel (Margaritifera falcata) which
formerly inhabited the river as evidenced in native American middens throughout the area is
now locally extirpated. This species exists for a portion of its development on the gills of
salmonids, and it apparently was unable to make th transition from chinook salmon when thy
were blocked by Swan Falls Dam. There may have been a few extinctions in the modern
fauna prior to disturbance, as I found two new (undescribed taxa which were not previously
known from the Pliocene or modern faunas) hydrobiid snail species in a Holocene deposit in
August, 1994. However, the dramatic collapse of the fauna has been very marked and has
. happened within the last twenty years.
In recent years pollution, seasonal diversion of water, sedimentation, impoundment, and other
disturbances have transformed the fauna to one more characteristic of warm, shallow lakes,
and nearly all of the fast, cold water requiring taxa are either endangered or are rapidly
becoming so (Frest and Bowler, 1992). Even in tailwater segments which are free flowing,
occurrence of the old fastwater fauna today is patchy and depauperate. Old, dead shells
indicate that the former species richness is disappearing very rapidly (for data on specific
reaches see: Frest, 1992; Frest and Johannes, 1991; 1992; 1993a; 1993b; Neitzelan Frest,
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1993; Bowler, 1991; Frest and Bowler, 1992).
The free-flowing reaches exhibit the consequences of long term lack of seasonal flushing and
the natural hydrologic regime, as well as the impacts of hydroelectric peak-loading,, or diurnal
fluctuations of water level in the tailwaters. Lack of flushing has resulted in a fine mud many
meters in depth blanketing the benthos and the thalweg, as well as a lack of seasonal
scouring of the riparian and littoral zones. Anoxic conditions develop in the benthos early in
the spring, often by april. Because of the lack of flushing and scouring, riparian vegetation
along the shoreline does not exhibit the formations. The free-flowing, lotic segments do,
however, sustain a unique and rare deciduous riparian forest formation comprised primarily
of hackberry and river birch. The riffle and littoral zones of the lotic sites caused by
interruption of sediment flow due to the dams and altered hydrologic regime, and also due to
historic peak loading (fluctuating the water level on a daily basis to track electrical need).
Exotic Organisms
Exotic plants which are problematic in the riparian zone include trees such as Russian olive,
teasel, and watercress, though there are many, many others as there are in most wetland
settings. Wetland in general appear to support more species of exotic plants than upland
habitats (Bowler an Wolf, in press). Watercress, am Old World annual species, has
dramatically altered spring habitat in the area, as well as many shallow areas in the mainstem
Snake River by blanketing the shallows with a closed canopy of growth. During the past
several years purple loosestrife, a pernicious invasive species, has become increasingly
abundant along various reaches in the Middle Snake River, and it can be expected to expand
its presence. Overgrazing has reduced riparian vegetation along many reaches, particularly
those in the public domain, and, for example, there is little riparian vegetation along in the
reach below Bliss Dam.
There are three exotic molluscs present in the mainstem river, including the Old World
aquarium snail Radix auricularia, the New Zealand mudsnail Potamopyrgus
antipodarum}Bow\er, 1991, and the Asian clam Corbicula fluminea. Radix has low population
levels and is not an ecologic problem, but the New Zealand mudsnail has become the
dominant mollusc in the river and many of its tributaries (Bowler and Frest, 1991). It covers
the undersides of rocks, macrophytes, and algae, and has astonishingly high population
densities ranging into the hundreds of thousands per square meter. Corbicula is a problem
mollusc in other parts of the country, however, has not developed large populations in the
Middle Snake River and appears to be restricted at present to the area above the Indian cove
Bridge. It has the potential to develop enormous populations, however, and could become a
serious concern if it is spread to other reaches. There are a number of exotic snails present
in the thermal plumes associated with tropical fish farms, however, they appear to be largely
restricted to these sites though some may extend their presence into the river during the
summer when the water becomes warmer (Bowler and Frest, 1992).
The introduction of exotic fishes has a long history in the Middle Snake River. Carp were
present in the river by the 1890s and a sequence of plantings by individuals such as
Ridenbaugh and the Idaho Department of Fish and Game led to the establishment of a wide
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Water Criteria and Standards for the 21st Century
range of non-native fishes (Bowler and Frest, 1992). Tropical fishes have escaped from
warm-water hatcheries, and recently (August, .1994) a piranha was caught by hook and line.
Non-native game fishes range from rainbow trout of non-Snake River origin to yellow perch,
crappie, largemouth and smallmouth bass, catfish and others (Bowler and Frest, 19922).
There is concern that the walleyed pike, which has been caught in the pool below the Twin
Falls power plant and exists in Salmon Falls reservoir, could enter the system. Were this to
occur, significant impacts might follow due to its carnivorous and predatory habits.
A History of Degradation, Extinction, and Habitat Loss
The Middle Snake River has a history of ecologic degradation and habitat loss which is both
a lesson in reckless development and an embarrassment in lack of foresight - as well as a
natural resource tragedy. Early dams eliminated the salmon and sturgeon runs, though
steelhead reinvaded the Middle Snake River after the installation of a poorly sited and
marginally operable fish ladder at Swan Falls Dam. Similar inadequate fishways were installed
at the rebuilt Lower and Upper Salmon Dams. Subsequent dams (Bliss Dam, C.J. Stirke Dam)
lacked ladders and blocked steelhead, but all anadromous access was ended by the Hells
Canyon projects. Early diversion for irrigation dismantled the natural hydroperiod and flushing
from runoff, and the tributary springs from the Snake River Plain Aquifer were nearly
completely developed for aquaculture, hydroelectricity, or were diverted for irrigation or
domestic purposes. Cities such as Twin Falls contributed waste streams, and a seemingly
endless list of non-point contributions paid their toll (Bowler, et al, 1992). At present there
are over 560,000 acres irrigated with water diverted from the Snake River, another 370,000
acres are irrigated with aquifer water; there are approximately 140 fish hatcheries; there are
five existing mainstem hydroelectric projects and seven more have been proposed; two
municipal sewage treatment plants; and over 600 dairies along the river - all of which
contribute to the declining conditions in the aquatic ecosystem (Bowler, et al, 1992). Impacts
have further been exacerbated by a pattern of decline in aquifer-fed tributaries in recent years.
The result of nearly a century of ecologic disruption has produced a river which is rapidly
changing from its original biology, now only present in remnant species and patches of
marginal habitat, from a coldwater lotic environment to that of a eutrophic lake. This pattern
is not uncommon in rivers with heavy nutrient loads, seasonal diversions, and sequential
dams. In both the impoundments and the free-flowing tailwaters macrophytes (mostly several
species of Potamogeton) and green algae dominate the shallow littoral zone. Carp are the
most common fish in many areas, the non-native New Zealand mudsnail has replaced the
native lotic fauna, and the benthos are altered from a rock, cobble, and sand (heterogeneous)
substrate to a uniform deposit of black, anoxic mud meters deep.
The Promise of Ecological Risk Assessment and TMDLs
"In the past, ecosystem risk has not been of much concern. Society believed that the supply
of some resources was infinite, that ecosystem destruction was a necessary component of
progress, that ecosystems not being harvested were of no benefit to society, that any use
was harmless until evidence of harm became direct and dramatic, and that technological
advances would continue to correct any problems resulting from destruction of natural
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resources. These beliefs have been challenged in the last part of this century, and public
attitudes in developed countries have undergone a remarkable transformation. Public priorities
have shifted to embrace environmental values."
John Cairns, Jr. and B.R. Niederlehner (1992)
Ecological risk assessment in its current state can be viewed as being comprised of three
primary components: problem definition; "a scientific risk assessment compares a prediction
of the level of stress that will occur in the environment after some human activity to a
prediction of likely biological effects at that level of stress; this comparison is used to estimate
the probability of adverse effect" (Cairns and Niederlehner, 1992); and then predictions of risk
are compared to "observed effects in natural systems for the purposes of quality control and
validation of methods for risk prediction" (see Cairns and Niederlehner, 1992, for further
discussion). Ecologic consequences of arrays of pollution loads, for example, are predicted
usually employing biomonitoring of individual indicator organisms or on multispecies evidence
(see, for example. Cairns, et al, 1994; Cairns, 1988; 1990). The resilience of a heavily
perturbed system such as the Middle Snake River in which large elements of the fauna are
extinct, the natural hydrology irreversibly altered, heavy pollution loads both in solution and
in sediments, and the physical benthic habitat simplified to a homogeneous frequently anoxic
substrate, is not easy to predictively model, however, species richness of the lotic mollusc
community does provide one means of assessing predictive success. The mollusc diversity
within the Middle Snake River has been well studied on a reach by reach basis, and has been
declining even within the past few years (Frest and Johannes, 1992; 1993a; 1993b). Species
richness and the robustness of populations of lotic taxa, including the Candidate, Threatened,
and listed Endangered species, would be one means of determining river health. Macrophyte
abundance, another measure,, is challenging because of absorption of nutrients from both the
water column and the sedimentary substrate; nonetheless, macrophyte response to varying
pollution loads can be predictively modelled based on TMDL concepts and load budgets.
Polluting industries which have in a sense become dependent upon the "natural resource
welfare" of continuing to degrade the aquatic environment without adequate mitigation for
the pollution they generate should be expected to support a budget concept as opposed to
more hardcore regulatory action such as directly limiting production. Thus, the TMDL model
would reduce nutrients in the water column with predicted ecologic outcomes. Ongoing
monitoring and adjustment of the model will be critical as the concept is implemented.
Suction dredging key reaches such as macrophyte colonized areas of Upper Salmon
Impoundment would be one means of reducing macrophyte dominance. The concept of
"flushing" sediment out of any river section places the reaches and impoundments below at
ecologic risk as a re-suspension of nutrients would likely exacerbate algal and macrophyte
problems downgradient. And, of course, sediment would simply fill lentic areas downstream
be they in impoundments or the already loaded naturally deep holes in sturgeon. It is unlikely
that the "salmon flushing flows" will move significant quantities of sediment from the Middle
Snake River.
Among the actions proposed by the Idaho Department of Health and Welfare, Department of
Environment (IDHW-DEQ) are the implementation of industry self-policing plans and goals
within 5 years, achieving cold water biota state (Idaho) dissolved oxygen standards within 5
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Water Criteria and Standards for the 21st Century
years, reducing aquatic vegetation (primarily macrophytes) below "nuisance" levels within 5
years, including a reduction of plant biomass by 30% and a reduction in sediment input of
30% (IDHW-DEQ, July 11,1994). These goals are not a TMDL approach per se and ignore
species richness or population indicators among sensitive taxa such as the molluscs, but could
reinforce early TMDL endeavors. Beyond five years, if implemented, TMDLs would clearly be
required to continue to better water quality so that the crash in the lotic ecosystem can be
arrested.
TMDLs based on modelling for individual reaches are one means of escaping the conspicuous
pitfalls of instantaneous measurements of pollution load to a daily budget concept, which
allows more even handed regulatory consideration and a better overall prediction of ecologic
outcomes of regulated pollution loads. There is presently an excellent opportunity to involve
ecosystem restoration actions with FERC re-licensing conditions, and this should be vigorously
explored by both state and federal regulators. It is critical to involve the FERC, as it is still
processing new hydroelectric project license applications despite state and Northwest Power
Planning Council "protected area" designations for the Middle Snake River. Instream flow and
other concerns will be central to the success of the TMDL approach, and new license
condition opportunity can be a strong asset. This could be further strengthened by the
Northwest Power Planning Council's wildlife enhancement plan.
Despite our best intents, there will be surprises - which perhaps modelling can anticipate. For
example, peak loading water fluctuation has been known to have a severely deleterious impact
on littoral river invertebrates since its initiation in the early 1950s. A reduction of substantive
peak loading in recent years has worked to the benefit of sensitive invertebrate taxa by not
forcing them to endure daily wetting and drying (or eliminating them from the littoral zone
entirely), yet because of the nitrate and phosphate load borne by the water it has allowed
macrophytes to expand their presence and for green algae to completely cover rocky littoral
habitat. Riparian vegetation, no longer scoured by seasonal runoff, has also expanded on
partially submerged point bars. In other words the benefit of terminating diurnal water
fluctuation which damaged snail populations has been reduced because of an encroachment
of algae and macrophytes on the environment protected by a stable water level. Thus, the
TMDL budget is needed to work with and allow protective water management operations to
succeed in assisting ecosystem recovery. This example also shows why prediction is needed,
as the consequence was not anticipated yet is obvious in retrospect. In conclusion,
dovetailing physical remediations with TMDLs and FERC license conditioning, ecological risk
assessment is our best hope for arresting the present ecological decline and transformation
presently underway in the Middle Snake River.
Literature Cited
Bowler, P.A. 1991. the rapid spread of the freshwater hydrobiid snail Potamopyrgus
antipodarum (Gray) in the Middle Snake River, Southern Idaho. Proceedings of the Desert
Fishes Council 21: 173-182.
Bowler, P.A. and T.J. Frest. 1992. The Non-Native Snail Fauna of the Middle Snake River,
Southern Idaho. Proceedings of the Desert Fishes Council 23: 28-44.
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Bowler, P.A., C.M. Watson, J.R. Yearsley, and P.A. Cirone. 1992. Assessment of
Ecosystem Quality and its Impact on Resource Allocation in the Middle Snake River Sub-Basin.
Proceedings of the Desert Fishes Council 24: 42-51.
Cairns, J., Jr. 1982. Restoration of Damaged Ecosystems, pp. 220-239. in Mason, W.T.,,
Jr. and S. Iker (eds.). Research on Fish and Wildlife Habitat. Office of Research and
Development. U.S. Environmental Protection Agency, Washington, DC EPA-600/8-82-002.
Cairns, J., Jr. 1988. Should Regulatory Criteria and Standards be based on Multispecies
Evidence? the Environmental Professional 10: 157-165.
Cairns, J., Jr. 1990. The Genesis of Biomonitoring
Environmental Professional 12: 169-176.
in Aquatic Ecosystems. The
Cairns, J., Jr., P.V. McCormick, and B.R. Niederlehner. 1944. Bioassay and Field
Assessment of Pollutant Effects, pp. 267-282. Jo Rai, L.C., J.P. Gaur, and C.J.
Soeder (eds.). Algae and Water Pollution. E. Schweizerbart'sche Verlagsbuchhandlung,
Stuttgart.
Cairns, J., Jr. and B.R. Niederlehner. 1992. Predicting Ecosystem Risk: Genesis and Future
Needs, pp. 327-343. Chapter 15 in Cairns, J., Jr., B.R. Niederlehner, and D.R. Orvos (eds.).
Predicting Ecosystem Risks. Advances in Modern Environmental Toxicity, Vol. 10. Princeton
Scientific Publishing Co., Inc. Princeton, New Jersey.
Frest, T.J. 1992. Mollusc fauna in the vicinity of three proposed hydroelectric projects on the
Middle Snake River, Central Idaho. Supplemental Report on the California Floater, Anodonta
californiensis Lea, 1852. (Unpublished) Report prepared for Don Chapman Consultants, Inc.
Boise, Idaho. 5 pp.
Frest, T.J. and P.A. Bowler. 1992. A Preliminary Checklist of the Aquatic and Terrestrial
Mollusks of the Middle Snake River Sub-Basin. Proceedings of the Desert Fishes Council 24:
53-58.
Frest, T.J. and E.J. Johannes. 1991. Mollusc fauna in the vicinity of three proposed
hydroelectric projects on the Middle Snake River, Central Idaho. (Unpublished) Report
prepared for Don Chapman Associates, Inc., Boise, Idaho. 60 pp.
Frest, T.J. and E.J. Johannes. 1992. Distribution and ecology of the endemic and relict
mollusc fauna of Idaho TNC's Thousand Springs Preserve. (Unpublished) Report (contract:
#IDFO 050291-A) to The Nature Conservancy of Idaho. 291 pp.
Frest, T.J. and E.J. Johannes. 1993b. Mollusc survey of the Minidoka Dam Area, upper
Snake River, Idaho. (Unpublished) Report (Contract #1425-22-PG-10-16780) to U.S.
Department of the Interior, Bureau of Reclamation. 36 pp.
Gilbert, C.H. and Evermanmnn, B.W. 1894. A Preliminary Report Upon Salmon Investigations
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in Idaho in 1894.
Water Criteria and Standards for the 21st Century
Hershler, R., T.J. Frest, E.J. Johannes, P.A. Bowler, and F.G. Thompson. 1994. Two New
Genera of Hydrobiid ,Snails (Prosbranchia: Rissooidea) from the Northwestern United States.
The Veliger 37(3): 221-243.
Langenstein, S. and P.A. Bowler. 1991. On-going macroinvertebrate analysis using the Biotic
Condition Index and the appearance of Potamopyrgus antipodarum (Gray) in Box Canyon
Creek, Southern Idaho. Proceedings of the Desert Fishes Council 21: 183-194.
Murphey, K.A., M.J. Freeman, and P. Bowler. 1993. Valley of the Mighty Snake: An
Overview of the Cultural an Natural History of Hagerman Valley, Southwestern Idaho.
Hagerman Valley Historical Society Report No. 1. J & D Printers, Castleford, Idaho.
Neitzel, D.A. and T.J. Frest. 1993. Survey of Columbia River Basin Streams for Columbia
Pebblesnail Fluminicola columbiana and Shortface Lanz Fisheriolanuttalli. (Unpublished) Report
prepared for the U.S. Department of Energy under Contact DE-AC06-76RLO 1830. Pacific
Northwest Laboratory-8229, Rev. 1, UC-606.
Simpson, J. and R. Wallace. 1978. Fishes of Idaho. The University Press of Idaho, Moscow,
Idaho.
Smith, G.R. 1978. Biogeography of Intermountain Fishes. Great Basin Memoirs no. 2: 17-
42.
CONFLICTING USES AND THEIR IMPACTS
Bob Muffley
Gooding County, ID
Gooding, ID
The Middle Snake River provides multiple important uses including recreational opportunities,
hydroelectric power, irrigation for agriculture, aquaculture and support for fish and wildlife.
By 1988 it became clear to the people in surrounding counties that the Middle Snake River
was dying. By 1989, county groups began working with state and federal agencies to help
facilitate problem solving by forming the Middle Snake River Study Group. The Study Group
worked closely with these agencies and hydroelectric, agriculture and aquaculture
stakeholders. Several problems were recognized. Sources of water entering the river were
return flows from irrigated land. In addition eight years of drought resulted in the mining of
underground water and natural springs were being depleted. Recharge of the underground
aquifer had been altered. After several years of effort by the Study Group that included
significant public involvement, a management plan was adopted by the three counties that
was tough but fair. The objective was to maintain the economic viability of the region. It is
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important to recognize that multiple uses of the river may or may not be conflicting. They
were out of balance.
Larry R. Wimer
Manager, Hydro Relicensing & Compliance
Idaho Power Company
Boise, ID
The conflicting uses in the Middle Snake River include aquaculture, agriculture, POTW's (both
river discharge and land application), and confined animal feeding operations. There are also
five hydroelectric projects on this stretch of the river. Along 90 river miles there are
approximately 25 miles of impounded reservoirs. Concerns associated with these uses
include reduced flow velocity, temperature change, nutrient loads and the need for water to
flush the system. To manage these uses and the ecological resources in the watershed,
appropriate and responsible actions and management decisions should be based on scientific
work. Idaho Power has conducted 27 studies as part of relicensing. Several years ago, Idaho
Power had only three environmental staff; now there are 51. They have also worked hard to
include the public in the relicensing process.
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Water Criteria and Standards for the 21st Century
MANAGING CONFLICTING USES IN THE MIDDLE SNAKE RIVER
Kevin J. Beaton
Deputy Attorney General
Environmental Affairs Office
Idaho Office of Attorney General
Boise, ID
Abstract: Water rights issues are a problem in the Middle Snake River. For example, the
Idaho Supreme Court recently made a decision which involved the application of fresh water
springs (a 1905 water right). Over the last two years water could not be delivered to a farmer
because water was being extracted from ground water many miles away. The decision
requires the Idaho Water Resources Board to manage surface water and ground water
together and therefore provide water to the farmer. To resolve the problem the Board
purchased water for the farmer. Other issues relate to requirements under the Clean Water
Act Section 303(d) listing and TMDL requirements, and Section 404 issues in water quantity
and flows in relicensing. These difficulties highlight the central point, people in the watershed
want water conditions to improve. They are interested in developing effective management
options.
I. INTRODUCTION
The Snake River is known as Idaho's working river since it is the essential natural resource
supporting the successful agricultural economy in southen Idaho. Water quality conditions
in the middle Snake River have significantly deteriorated for the past decade. The causal
factors are relatively simple to identify. There is too much sediment and nutrient discharged
to the river. Addressing water quality problems in the middle Snake River while maintaining
the agriculturally-based economy that depends upon the river, is a much more difficult
problem.
Public concern about water quality conditions on the middle Snake River has culminated in
industries, citizens, and local governments coming together with state arid federal resource
agencies for the purpose of developing plans to address long term water quality
improvements.
In developing a plan to restore the river, the state has been and will continue to be utilizing
watershed ecological risk assessment models as tools to predict the risks and results of
proposed regulatory and non-regulatory pollution controls. Public acceptance of the validity
of the watershed ecological risk assessment approach is essential to implementing the
necessary changes in state laws, regulations, politics, and the way people conduct their lives
to clean up the river.
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II. DESCRIPTION OF THE RIVER
The Snake River begins in the high mountains within Teton and Yellowstone National Parks
and flows for hundreds of miles through southeastern Idaho along the arid Snake River Plain,
supplying water and electricity to the agriculturally-based economy. The Snake River is the
major waterway in southern Idaho. Flows in the upper Snake River are dictated by winter
snow pack and spring melt in the mountains, and operation of numerous Bureau of
Reclamation storage reservoirs. By the time the river reaches southcentral Idaho, where the
middle Snake River begins, water in the river has been impounded and diverted numerous
times.
The upstream boundary of the middle Snake River is Milner Dam. From below Milner Dam,
the middle Snake River flows over ninety miles, descending 1,600 feet through spectacular
basalt canyons. Although flows in the river are low or nonexistent below Milner Dam during
certain times of the year, the river is recharged by fresh water springs throughout this reach.
One popular area along the river is known as the "Thousand Springs" area where numerous
springs issue forth from the canyon walls and drop hundreds of feet to the river below.
During low flow periods, fresh water springs account for over 2/3 of the flow on the river.
The source of the fresh water springs is the Snake River Plain Aquifer, one of the largest
aquifers in the United States which extends hundreds of miles north and east of the middle
Snake River watershed.
Idaho's water plan recognizes that the Snake River is fully appropriated at Milner Dam. In the
past, it has not been unusual for the river to be dry below the dam during irrigation season.
Hardly an auspicious beginning for a large river with significant water quality problems. Water
that is impounded and stored above Milner Dam and other upstream storage reservoirs
supplies water to irrigate over half a million acres in the middle Snake River watershed for
agricultural production through a series of large canals that extend for hundreds of miles.
III. LOCAL INDUSTRY
The land along both sides of the middle Snake River is known as the Magic Valley. The
economy in the Magic Valley is largely dependent upon agriculture. At the turn of the
century, the terrain in the Magic Valley was largely arid high plains steppes. The construction
and operation of dams and canals along the river significantly transformed changed the
landscape. Today, the Magic Valley consists of tracts of farms and rangeland, and is one of
the most productive agricultural areas of the state. Return flows from irrigated agriculture in
the summer and early fall account for a significant amount of the flow in the river. Not
unexpectedly, irrigation return flows to the river contain sediment and nutrients which
contribute to water quality problems in the river. Dairies or confined animal feeding operations
(CAFOs) are a high growth industry in the Magic Valley. Nutrients and bacteria generated
during dairy operations may be discharged to surface and ground water, thereby contributing
to the enrichment of the river.
The cold, well oxygenated and clean fresh water springs that recharge flows in the middle
Snake River provide the aquaculture industry with an essential natural resource. Over one
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hundred commercial fish hatcheries in the Magic Valley utilize the fresh water springs to grow
Idaho rainbow trout. It has been estimated that over 70% of the commercial trout produced
in the United States are produced in Magic Valley fish hatcheries. The total production from
Magic Valley fish hatcheries is approximately 40 million pounds of fish annually. Fish
hatcheries are subject to EPA IMPDES permits which set forth limits for the discharge of solids
to the river. Nevertheless, fish hatcheries contribute substantial amounts of dissolved
nutrients to the middle Snake River annually which also contributes to enrichment of the river.
Numerous publicly owned sewer treatment plants along the river also discharge substantial
amounts of dissolved nutrients, to the river which serve the growing population and food
processing industries. On the middle Snake River below Milner Dam, there are presently five
dams which are used to generate electricity. These hydroelectric facilities help supply Idaho's
citizens with some of the most inexpensive electrical rates in the United States. The
hydroelectric facilities also change the hydrology of the river through peaking flows and
impoundment of water. These changes result in an increase in water temperatures,
encouragement of sediment deposition, increased algae blooms and modification to aquatic
species in the river.
A final ecologic stressor is mother nature. Flows in the upper Snake River are largely
dependent upon snow melt in the spring to fill the large storage reservoirs. Since 1987, Idaho
has been in a severe drought condition, similar to conditions documented in the 1930s. The
resulting low flows in the middle Snake River have exacerbated poor water quality conditions.
IV. WATER QUALITY CONDITIONS
As a result of sediment runoff from irrigated agriculture, nutrient discharge from fish
hatcheries and sewage treatment plants, and other agricultural operations, low flows from
upstream impoundments, drought, and the operation of hydroelectric facilities, water quality
conditions on the river are poor.
For the past ten years, water quality on the middle Snake River has been a noticeable
problem. Rooted aquatic plants, filomentous algae alternating with plankton blooms seemingly
take over the river from late spring through fall. In some areas, the surface of the 1/4 mile-
wide river is entirely covered by macrophytes and algae. During most of the summer, it is
difficult or impossible to boat or water ski in the river.
Beginning in 1990 through today, the state of Idaho along with EPA and local governments
began studying the river to determine the sources and levels of pollutants going into the river
and the extent of water quality problems. The results of those studies have confirmed initial
suspicions that the river is overloaded with nutrients, organic solids, sediment and aquatic
plants. The native aquatic species, particularly salmonids and the macroinvertebrates they
feed upon, are being displaced by pollution-tolerant species such as carp, suckers and an
exotic snail known as the New Zealand Mud Snail. In some areas these snails cover
submerged surfaces at densities up to 8,000 snails per square meter. Degraded conditions
on the river have also led to the listing of a number of native mollusk species as endangered
under the Endangered Species Act. The original cobble substrate of the river has become
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entirely covered in some areas with sediment and organic materials from two to twelve feet
in depth. Dissolved oxygen concentrations often have been recorded near zero on the bottom
of the river or in deep weed beds. As a result of the excessive plant growth and sediment
deposition, most designated uses for the river established under the Clean Water Act and
state water quality standards are impaired and narrative and numerical criteria are frequently
exceeded.
WHAT IS BEING DONE TO ADDRESS WATER QUALITY PROBLEMS
As a result of the documented water quality conditions on the river, the middle Snake River
was designated as "water quality limited" under § 303 of the Clean Water Act. In lieu of
proceeding with a traditional total maximum daily load approach, the state, in partnership with
the EPA and local governments has been actively pursuing the development of a nutrient
management plan under state authorities. Since 1991, local governments, industries, citizen
groups, and state and federal resource agencies have come together as the middle Snake
River Nutrient Planning Group to reduce nutrient and sediment discharges to the river. The
first phase of the plan will establish target goals for each industry to reduce their pollutant
loadings by significant percentages through best management plans and other modification
to industry practices. It is hoped that a reduction in pollutant loading from all industries will
eventually result in a reduction in plant growth. In developing the goals of the plan, the
planning group has relied upon ecologic risk assessment in helping to establish the goals of
the plan and the expected results.
As the plan has developed, it is becoming increasingly clear, through the, use of watershed
ecological risk assessment, that the reduction of pollutant loading alone will not restore the
river. More water is needed in the river to scour and flush sediment in the river substrate
which has accumulated for decades. The volume of nutrient-rich sediments in the river
combined with shallow water depths will continue to support nujsance plant growth. Studies
are ongoing to determine the water velocities necessary to flush sediment down the river.
Whatever the final result of those studies are, significantly increased water flows through the
middle Snake River during certain times of the year will be necessary to wholly restore the
river and maintain habitat. It is not known where that water will come from. The Snake River
is fully appropriated before it reaches the middle Snake River.
Almost all of the storage space in upstream Bureau of Reclamation reservoirs has been
contracted or is otherwise committed. Fresh water spring flows into the middle Snake River
from the Snake River Plain Aquifer have been declining for the past thirty years due to more
efficient irrigation practices which has reduced ground water recharge combined with ground
water diversions hundreds of miles away. There is also concern that the ground water may
become contaminated.
Because the Snake River is fully appropriated, the state has been going through a
comprehensive water rights adjudication since 1986 to determine over 150,000 claims to the
Snake River basin water. By all accounts, it appears that the litigation may last well into the
21st Century. Whatever the final resolution of the Snake River adjudication may be, it will
likely not result in any increased flows in the middle Snake River for water quality purposes.
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Water Criteria and Standards for the 21st Century
The underlying doctrines in western water law of "first-in-time, first-in-right" and "use it or
lose it" are firmly established in Idaho water law. Consequently, any newly established
instream flows as a water right for instream beneficial use will continue to have too late of
a priority date to have any meaningful benefit to water quality on the middle Snake River.
The Endangered Species Act has and will continue to impact upon water flows and water
quality issues in the middle Snake River. In an effort to provide additional water to ease
northwest salmon downriver, the Bureau of Reclamation has released committed water from
upstream reservoirs in 1994. However, this amount of water was not sufficient to flush the
sediment in the middle Snake River however. It is expected that there will be increasing
demands upon the Bureau of Reclamation to release more water in the coming years for
salmon. The state, through the middle Snake River planning group, is working with the
Bureau of Reclamation to time the increased flows to ensure the most benefit to water quality.
Recovery plans for endangered snails found in the middle Snake River are currently being
prepared. It is expected that the plans will propose require improved water quality and
increased and stable flows in the river. Again, it is not known where the additional water will
come from.
The present conflicting uses in the middle Snake River are also a product of conflicting
national policies and goals established throughout the Twentieth Century. The well-
intentioned national goals of settling the arid west, establishing and maintaining agriculture
production, and encouraging hydroelectric development to provide inexpensive power
seemingly conflict with later goals of protecting the biological integrity of our nation's water
and protecting endangered species.
In light of these conflicting uses, it is clear that there are no easy solutions. Economical
modifications to industry practices affecting water quality in the river may not be enough to
restore the river and protect native aquatic species. Significant changes in state law and the
way people conduct their businesses may be necessary to restore the river. The much
heralded and often illusory confrontation between the economy and the environment seems
a reality in the middle Snake River.
The middle Snake River offers a good example of why it is essential to expand the analysis
of water quality issues beyond point source controls and water column chemistry as we
assess ecological stressors from throughout the watershed. Water diversions and reservoir
operation decisions hundreds of miles away have impacts on water quality in the middle
Snake River. Likewise, land management practices throughout the middle Snake River
watershed have impacts on what pollutants reach the river and ultimately affect water quality.
In retrospect, the use of watershed ecological risk assessment models when the Clean Water
Act was first passed in 1972, might have predicted current water quality conditions on the
middle Snake River and other western rivers. It is now clear that water quantity issues and
nonpoint source controls, not addressed in the Clean Water Act, are essential components to
achieving the goals of the Clean Water Act. Appropriation of state water and the regulation
of land management practices should increasingly recognize water quality issues. It is
essential that policymakers have a clear understanding of the consequences of their actions.
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The use of watershed ecological risk assessment can assist policymakers and especially the
general public understand the consequences of their actions and the risks involved in choosing
a course of action and the benefits to be obtained. To be effective, ecological risk
assessments must not only identify environmental stressors, establish priorities, and provide
a scientific basis for regulatory actions, but the general public and policymakers must believe
assessments can do all these things and be willing to act according to risk assessment
projections.
Don Brady
Watershed Branch
U.S. EPA - Office of Wetlands,
Oceans & Watersheds
Washington, DC
The watershed protection approach focuses on the resources to be protected. This involves
geographic targeting (e.g., a certain reach of a water body) and the identification of threats
to human health and aquatic resources. The approach depends on the involvement of
stakeholders and focuses on developing integrated management actions. Data sharing is
essential to ensure that all quality information is used in the evaluation. The culture and
customs of the stakeholders must also be addressed; the process is not only scientific and
technical. The Middle Snake River management efforts provide a perfect example of this
process.
ISSUES AND RECOMMENDATIONS FROM DISCUSSION:
• We need to understand the ecosystem and need data to develop a logically derived
problem statement. An ecological risk assessment is a process for collecting,
compiling, sorting and evaluating information.
• The processing of information in a risk assessment helps educate everyone in the
watershed and places them on the same level playing field so they can discuss issues.
• Peer pressure can be an effective tool for obtaining environmental protection. When
members of the public understand the problems, they pressure their neighbors to meet
agreed upon actions.
• Data sharing is critical to success. USEPA could play a role as "data bankers."
^
• Effective legal actions depend on good science. This helps to determine workable
options for management. These options should be based on what can be regulated
and enforced.
• Private industry needs to know the rules and have them consistent. These rules need
to be "black and white" not gray when it comes to implementing laws.
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Water Criteria and Standards for the 21st Century
SESSION 3 - Questions and Answers
Q: With respect to the Australian snails, if the water were clean, would they increase in
population?
A: No, if water were colder and cleaner, there would hardly be any.
Q: Was there any discussion about retiring agricultural use of the river?
A: Idaho is revising their plan - not to eliminate the above ground irrigation, but irrigation
done through pumping from the underground aquifer (about 300,000 acres). If you
want a good spring level, then the above ground irrigation (which recharges the
aquifer) is needed.
Q: What types of crops are grown in the area?
A: You can grow anything. Main crops include potatoes, beans, hay, and corn. With
respect to hay, there are about 600 dairies with about 2000-5000 cows each.
Q: Pat Cirone: Is there anyone here from west of the Mississippi? (Some participants
raised their hands.)
Q: Do you understand water law? Some participants raised their hands.
Q: Is agriculture contributing nutrients to the river?
A: There are two sides of the river. On the north side, there is lava. They have to use
pivotal circular sprinklers to water. On the south side, there is no ability to sprinkle.
The south side contributes 80% of the loading.
Q: What about tail water recovery?
A: Yes. One company put in a wetlands area. Other places are looking at it, but this is
not the whole answer. We need to clean up the water.
C: On the north side is volcanic soil. On the south side, these are old lake beds. It is
very rich fine soil. (Peter Bowler)
Q: Could you highlight the components of the plan?
A: The plan addressed every major use on the waterway and involved the public. It
addressed hydroelectric power, industries, local government uses, individual septic
systems, agriculture, aquaculture, recreation and tourism - on a BMP basis.
The counties have no ability to create laws, but mechanisms to coordinate with State
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and Federal agencies. For example, all new development on the Middle Snake River
was stopped.
Canal companies started to work based on the plan. It is important to note that the
entire commission is made up of farmers.
Q: When people reached consensus, was economics considered?
A: Some components are quite easy to implement. For BMPs proposed by the farmers,
the economic impact is minimal. A problem with Federal plans is that they don't
always address the culture of the region. You need local people to work with you on
the plan.
Q: It was stated that 6,000 cfs would be needed for the flushing over several months.
Did you consult with an expert regarding that number? Possibly a higher number such
as 30,000 cfs for a shorter period of time would be sufficient.
A: It's not our number. Peak flows really flush out. It may be something you could do
with the natural morphology.
Q: How does environmental mitigation fit into your relicensing?
A: In the relicensing process, you should know how the river functions and what the
impacts are. In our study, we looked at 27 different areas. We are now undertaking
our mitigation planning.
Q: To audience: How many local government representatives are in the audience? How
many State government representatives? How many Federal government
representatives? How many private representatives? Generally equal number of
various parties in the audience.
Q: In New Mexico, Indian tribes stream water quality are an issue. Is that an issue in this
area?
A: Yes. About 100 miles upstream from beginning of Middle Snake River, there is a tribe.
Also, there are a number of tribes downstream. They have an influence on
adjudication and relicensing.
C:' If water law applied in the Everglades, there would be no Everglades. The Everglades
Act is that water would be available forever for the Everglades. (Fontaine)
A: Idaho has adopted a public trust doctrine in that the public interest should be taken
into account in issuing new water rights. However, this does not affect the shuffling
of water rights.
C: Some suggestions for what Idaho might do are to construct mass balance models, buy
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the farms, and use land application of wastes for existing farms. (Fontaine)
A:
A:
C:
A:
C:
C:
Q:
A:
In Idaho, you can buy the farm, but you don't get the water right. Also, there are
problems with land application.
Regarding an issue with respect to TMDLs, there are only two sources with limits in
NPDES permits. These have a clout of cloutrThen there are the agricultural BMPs with
no clout. Is there any incentive to ensure that the BMPs happen?
There is some concern that non-point source controls aren't working and that you may
have to set up some mandatory requirements. The Federal government may have some
control on Federal land. However, they are looking at possibly changing State law.
If the State identified a stream as being impaired because of upstream diversion, could
the Federal government do something?
There would have to be changes to Federal/State laws.
Oregon has the same problem regarding with respect to water rights. However, they
have a State law that when a new application for appropriation of water comes to the
State Commission, it must be compared against the public interest. The results are
that a lot of appropriation applications have gone by the wayside.
Idaho has the same law.
(API): Industry can agree with the watershed approach, but let's look at a problem.
In the watershed approach, there may be an existing requirement that doesn't make
sense (e.g., technology-based standard) that would require a statutory or regulatory
amendment. How would you respond to amending statutes?
It's pretty clear that in a comprehensive approach you may find these situations.
Stakeholders should make these situations known and make a case. It doesn't mean
that the watershed approach is meant to replace EPA's total regulatory structure.
There may be other reasons for the requirements.
(API): Maybe EPA should keep this in mind during CWA reauthorization.
County has hammer - peer pressure. It has the right to subpoena and hold hearings.
It has used this in one situation successfully to bring in various agencies and the press.
This can be more powerful than regulations. (Muffley)
Will BMPs solve the problem?
I think it will, but we must stay on top of it. We must keep it in front of the public.
(Muffley)
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Q: In one case, we routed an entire creek through settling ponds. The ditch company
sued PRP for taking the water. This was a problem involving water rights and water
quality.
A: We had a situation which used a collaborative process; we routed water through old
hatcheries and then into wetlands areas. The irrigation company. Power Co., etc.
worked together to make it work without the federal government. (Wimer)
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Session 4
Comprehensive
Environmental
Programs Of The
Future:
Where Are We Now And
Where Are We Going?
1
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Water Quality Criteria and Standards Conference
COMPREHENSIVE ENVIRONMENTAL PROGRAMS OF THE FUTURE:
WHERE ARE WE NOW AND WHERE ARE WE GOING?
Margarete Heber
Health and Ecological Criteria Division
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
Session Moderator
SUMMARY
The conference's previous sessions introduced:
the tools available to regulators; and
the risk assessment process
Why is this session important?
Too much time is spent trying to catch up to the regulations and laws.
We can use this session to think about where we want to be in 5 years and the steps
we need to get there, using the tools discussed in the previous sessions.
Historically the Environmental Protection Agency's (EPA) water quality-based permitting
program has focused on controlling individual chemicals from specific point sources through
chemical specific criteria. Chemical specific water quality criteria are allowable concentrations
of a chemical pollutant which, if not exceeded in the receiving water, are protective of aquatic
life for an individual chemical. More recently, whole effluent toxicity (WET) testing was
developed to protect aquatic life from the effects of complex mixtures of chemicals, with
known and unknown toxicity, being discharged from point sources.
In addition, other types of chemical specific criteria/methodologies are being developed in an
attempt to protect other parts of the aquatic ecosystem which are not currently protected by
aquatic life criteria. These include sediment criteria for the protection of benthic organisms,
wildlife criteria, and a methodology to more consistently address highly lipophilic compounds
in all of the above types of criteria.
All of the criteria and or methodologies serve as both yard sticks to measure pollution and as
assessment tools for monitoring the health of a waterbody or watershed. Another type of
assessment tool which has been developed, which directly measures the health of the
ecosystem, as opposed to measuring stressor levels, are biological assessments or biological
criteria.
Environmental stressors to an aquatic ecosystem can be chemical, physical or biological in
nature, and likewise can impact the chemical, physical, and biological characteristics of an
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aquatic ecosystem. As our focus shifts to overall watershed protection, biological criteria and
assessments are important tools to add to detect the cumulative effect of stressors to aquatic
ecosystems.
EPA's Office of Water 1991 "Independent Applicability" (IA) policy builds on all these water
quality-based programmatic pieces (chemical specific aquatic life criteria, whole effluent
toxicity tests and biological assessments and criteria). The policy stresses the integration of
all of the three types of criteria/assessment tools and states that "each of these three
methods can provide a valid assessment of designated aquatic life use impairment. Thus, if
any of the three assessment methods demonstrate that water quality standards are not
attained, it is EPA's policy that appropriate action should be taken to achieve attainment,
including use of regulatory authority." The policy gives equal weight to all three tools and
their complementary abilities to detect impairment in a waterbody. Critics of the IA policy
have argued that if one type of measurement indicates attainment, it should override the two
that indicate nonattainment. An example of this is when either or both chemical criteria and
effluent toxicity are exceeded but biological surveys in the receiving water indicate no impact.
This has led to a heated controversy between the states and EPA over the last several years.
Since the promulgation of the National Toxics Rule (1993), all the states now have adequate
chemical specific water quality criteria in their standards so that the overall baseline of
information on chemical pollution in watersheds will increase nationally. Those states which
have had chemical specific water quality criteria in their standards and have utilized WET in
their NPDES permitting programs have established strong databases and continue to move
their water quality programs ahead.
A good example of a state that has moved ahead with their water quality-based programs is
North Carolina. They have implemented the watershed permitting program which in turn
allows them to use TMDLs as they were intended. They also have an active Pretreatment
program and an extensive and strong enforcement record with WET. The State believes that
they have a very good monitoring database composed of WET, chemical specific data and
biological criteria/assessments for most of their dischargers and waterbodies gathered over
a number of years. They are also making strides to assess and control non-point source
problems in those same waterbodies. Based on this extensive database they have recently
chosen to propose not re-adopting some chemical specific criteria in some waterbodies.
As attention is focused on implementation programs in watersheds, shouldn't the definition
of a good state water quality-based program be broadened to include all the water programs
(criteria, standards, non-point source programs. National Pollutant Discharge Elimination
System permits, enforcement, TMDLs, monitoring, or groundwater protection etc.), instead
of the narrow programmatic focus we've taken in the past? Shouldn't the definition of a good
state water quality program be comprehensive and flexible using all the tools available to
provide a balance in our decision making in watersheds? Won't this result in overall
environmental benefit to the watersheds we are trying to protect, support the state's
environmental programs and improve our overall ecosystem management by providing states
with flexibility based on good supporting data which has been gathered over many years?
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Session 4
Water Quality Criteria and Standards Conference
The participants of this session will be representatives from EPA, states, industry, and an
environmental group. They will be looking into their crystal balls to try and address these
issues, as well as the implications this type of approach might have for Clean Water Act
reauthorization, the Endangered Species Act, and current EPA Office of Water policies.
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Water Quality Criteria and Standards Conference
COMPREHENSIVE ENVIRONMENTAL PROGRAMS OF THE FUTURE:
WHERE ARE WE NOW AND WHERE ARE WE GOING?
Cynthia Dougherty
Director, Permits Division
Office of Wastewater Management
U.S. Environmental Protection Agency
Washington, DC
SUMMARY
Review previous points:
Do we have common view of comprehensive water resource management?
How do we balance need to continue to aggressively implement existing program while
recognizing what comprehensive approach may require?
How do we make environmental laws to achieve goals?
Approach for future pollution prevention
Informed community does better job than distant bureaucracy
Ecosystem management is top priority in administration
Edgewater consensus
fundamental reorganization in how we address remaining environmental problems
Existing problems all have to do with how we live.
Previous efforts have been fragmented
EPA has not paid sufficient attention to whole problem
place-based environmental management driven by problems
Watershed approach
Consider all water resource concerns
surface water and groundwater
apply tools to solve problems of greatest concern
Actions are driven by environmental objectives and strong science
high quality data
Stakeholder involvement
willingness to pay attention
Cross program coordination is an efficient allocation of resources
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Session 4
Office of Water Activities
Watershed policy committee
Interagency coordination
Comprehensive state programs ,
Remove impediments to integration of water programs
Improve coordination and collection of data
Task force
Natural strategies, plans for environmental data collection
National goals project
Identify goals
Develop ways to measure progress
Office of Water Strategic goals
Protect water supply
Enhance public health
Enhance ambient water quality
Reduce loading
Diagnostic tools development for watersheds
Integrated watershed grants
EPA grant programs structure make it difficult for states to take watershed
approach. EPA is changing.
NPDES watershed strategy - March 1994
Use old program to provide tools to move to watershed approach
synchronize permit decisions
develop a watershed basis for NPDES permitting
Issues
What do we do in the meantime as we develop approach to watershed
focus on stressors in watershed
work with other programs that have effects on watershed
Office of Water is committed to goal of comprehensive water resource management.
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Water Quality Criteria and Standards Conference
COMPREHENSIVE ENVIRONMENTAL PROGRAMS OF THE FUTURE:
WHERE ARE WE NOW AND WHERE ARE WE GOING?
Steve W. Tedder
Chief, Water Quality Section
Division of Environmental Management
North Carolina Department of Environmental, Health and Natural Resources
Raleigh, NC
SUMMARY
A balanced state program
What is a balanced program?
comprehensive
innovative
constantly look at resources and prioritize
dynamic
good political timing
Look at cash flow
appropriations
fee base
Look at staffing
North Carolina State Program
Monitoring program must be strong
Must have good biological component to the program, not just chemical
Also oxygen demand and sediment programs
Get into innovative monitoring
Monitoring is how to show successes and failure of the entire
environmental program
Design program so that information collected fills in information gaps
Non-point source program
Public can see non-point source problems, therefore very visible
Target agricultural issues to public resources to prioritize
Stormwater programs and controls (NC mandates land use controls)
Use more innovative approaches to enhance program and make it more
attractive to regulated community
WET Program - Most successful program in NC
NC has 90% NPDES compliance
Anything except purely domestic discharges have a WET limit
Biological state laboratory certification program to ensure quality of data
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Wetlands Program
Developing Program
Criteria and Standards Program
Nutrient sensitive waters have been identified and have standards on nutrients
Water Supply Protection Programs
mandatory land use planning
risk based approach - predictive
Pretreatment Program
Compliance Program
Other programs are only as good as enforcement and compliance
have increased compliance effort in state
Operator Training and Certification Program
NC requires for every treatment plant in state
NC Basin wide planning initiative
NC - 17 river basins
Evolutionary process - keep building on information you have - will develop way
to bring point source and non-point source programs together will give the
efficiency and effectiveness, consistency and predictability have put this
program in without additional staffing monitoring program in basin - designed
a nutrient trading mechanism can protect and enhance resource in the states
if have balanced programs.
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Water Quality Criteria and Standards Conference
COMPREHENSIVE ENVIRONMENTAL PROGRAMS OF THE FUTURE:
WHERE ARE WE NOW AND WHERE ARE WE GOING?
Michael A. Ruszczyk
Environmental Chemist
Corporate Health, Safety and Environment
Eastman Kodak Company
Rochester, NY
Abstract: Many in the regulated community believe that a well-crafted program for
comprehensive watershed planning can be the best approach to water quality protection. A
successful program must: (1 j prioritize watersheds in order to focus resources on the more
significant problems; (2) allow for a cooperative effort among stakeholders; (3) clearly identify
the problems causing impairments; (4) ensure a long-term phased approach based on sound
scientific and technical information; (5) ensure equability in terms of funding sources; (6) be
implementable through an appropriate balance of incentives and enforcement.
A watershed approach should be a program which supplants existing programs to some
degree rather than overlying an additional burden on regulatory authoriies and the regulated
community. Watershed planning decisions should be allowed to supersede certain existing
restrictions, such as the NPDES antibacksliding provisions.
Lakewide Management Plans (LaMPs) being developed for the Great Lakes may provide an
attractive model. Properly developed LaMPs offer great potential as an integrating mechanism
for Federal, State and local programs, watershed management plans, Remedial Action Plans
and other voluntary and regulatory programs. This holistic and integrated approach offers a
better process to achieve water quality standards.
SUMMARY
Intent is to provide an industrial perspective of watershed approach
GLI is inappropriately considered a model for watershed planning and management.
The initiative views the Great Lakes watershed as one ecosystem, and uses a one size
fits all approach
Problems: management and funding
obtaining adequate data
Uniform protection should be the goal - we need to assure nationwide consistency
Prioritize watersheds
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Session 4
focus on specific impacts
allow for education and involvement of stakeholders
ensure equitability in terms of funding sources
use of positive incentives - market based incentives or pollution trading
Lakewide Management Plans such"as the Lake Michigan approach can provide a better
watershed planning model than the Great Lakes Initiative.
Identify impairment: e.g., overharvesting and introduction of exotic species
Process r
Causes and sources; of water quality impairment must be identified
Goals must be well defined
Funding must be equitable - it's not right to require the currently regulated
community to carry the cost burden of the program
Groundwater impacts on watersheds must be considered on a case-by-case basis.
Restrictive federal programs are not appropriate for this task.
Local agencies are in the best position to address these issues.
i
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Water Quality Criteria and Standards Conference
COMPREHENSIVE ENVIRONMENTAL PROGRAMS OF THE FUTURE:
A 21st CENTURY VISION OF EFFECTIVE STATE WATERSHED
PROTECTION PROGRAMS
Jessica C. Landman
Senior Attorney, Natural Resources Defense Council
Co-Chair, Clean Water Network Steering Committee
Washington, DC
A truly respectable State watershed protection program does the following:
A. Clearly and publicly defines goals for protection and restoration
1. Water quality standards are comprehensive (chemical, physical, biological;
cover all appropriate endpoints, including endocrine); new ones judiciously
selected and financed. (Example: pesticide manufacturers finance development
of Atrazine WQC.)
2. Water quality data are efficiently collected and answer critical questions with
minimum wasted energy, resources.
3. Use classifications have been carefully rethought and ambitiously established
to encourage restoration.
4. Outstanding waters have been identified through a process that builds massive
citizen support.
5. All key stakeholders know what to strive for, on what timeline - and know they
will be held accountable. Performance-based measures. Baseline protection for
everyone — i.e., cancer risk levels.
6. Is not necessarily limited to a single State's program - i.e., it adheres to natural
watershed boundaries. Exploits true potential of, e.g.. National Estuary
Program. Signals new era of cross-boundary cooperation. Taps potential of
multi-state arrangements like the Great Lakes Initiative.
7. Builds on technology-based programs, using those programs effectively:
a. Don't fight them, join them: Fully implements the effluent guidelines,
pretreatment and CZARA baseline technology (these programs also must
evolve to include, for example, pollution prevention in effluent
guidelines).
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8.
10.
1. Lets the Federal government do the work and take the heat.
2. Levels the playing field.
3. Concentrates State political muscle on the areas where it is truly
needed by not re-fighting each battle.
Fully engages the community in service of a shared goal
a. Citizens and affected industry engaged in triennial review and feel they
have a stake in achieving water quality goals.
b. Volunteer monitors are integrated into State/regional plans.
c. State/local planning agencies are part of water quality program process,
not an afterthought.
d. Waterbodies are posted for fishing and swimming safety, to help build
public momentum for cleanup as well as to help protect public health.
Takes integrated approach to environmental protection, beyond traditional in-
stream (or even water body-based) water quality considerations.
• 401 Certification process is fully exploited (flow, runoff sources, etc.)
• Coastal Zone Management Act/environmental agencies work hand-in-
hand
• Endangered Species Act considerations routinely included
• State pollution prevention office called for every major permit
renewal/issuance
• Clean air permits, mobile source programs cognizant of water quality
impacts
• Decisions on open space protection are based on knowledge of critical
ecosystems, Outstanding National Resource Waters (ONWR), source
water protection areas; tax and other incentives coordinated
• Database allows for special consideration for highly-impacted
communities, such as subsistence fishing communities
Flexibility: You Want It? You Gotta Earn It!
a. Best example: Requests for relaxing technology-based standards for
wet weather flows. These can't be expected to be accepted without
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Water Quality Criteria and Standards Conference
making a case. This means:
1) data on water quality impacts -- who, what, where
2) best efforts on finding enough resources
full implementation of other program components
3)
4)
sensitivity to current and future community needs (example:
combined sewer overflow policy focuses on urban recreational
waterways)
b. Enforcement -- prove you mean business and the public will be on your
side when you use enforcement discretion.
c. Total Maximum Daily Loads (TMDL's): do not expect miracles unless
and until the polluted runoff program gets some teeth.
Environmentalists won't buy a pig in a poke, but will buy one with a
fully operational manure management system that has an NPDES permit.
d. Treat water quality standards with respect. Independent applicability
makes sense. Why not make it work?
• Fix, do not belittle, chemical-specific standards. Use site specific
criteria where appropriate.
• Do biocriteria right the first time. Make them regional, if
necessary.
• WET is here to stay — support it. But should it be expanded to
ensure that estrogenicity is adequately addressed?
e. ITFM - example of how to earn flexibility. Support for fewer reports,
once it is clear reports will serve us better.
Conclusion: Same tax base, same goals: citizens, local. State and Federal governments are
all in this together.
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SESSION 4 - Questions and Answers
Q: Have talked about what is to happen in future, but what about implementation now?
What about enforcement and compliance of nonpoint source problems? They have had
BMPs for a long time but see no changes in water quality problems? (John Jackson,
Oregon POTW)
A: Congress did not reauthorize CWA this year. A part of this should be enforceable
programs for runoff control. Enforceable runoff programs are highest priority to
environmental groups. (Landman)
A: Several states have enforceable programs. NC has turbidity standard with caveat that
if industry (animal husbandry, logging, etc.) had BMPs in place it would not be a
violation. NC would like to see site-specific controls as opposed to across the board
controls. Trying to remove legislative barriers to go after nonpoint source problems.
(Tedder)
C: Perhaps move beyond CWA, possible Food and Drug. (Jackson, Oregon POTW)
Q: In using watershed approach, is there any problem you are experiencing from regulated
community and citizen groups in the way you have prioritized basins as far as a delay
in getting to the watershed? (Garreis, MD)
A: NC established schedules based on sensitivity of the basins and the amount of
information on a particular basin. We still keep all controls under other programs in
place so no basin is without controls. It is a way of managing resources and controls.
We haven't received any complaints. (Tedder)
Q: Need flexibility in grants to do watershed work. Look at analytical methods to keep
them current. EPA should go on the road with these tools once they are developed.
Bring them to stakeholders, not just in a national meeting. Independent applicability,
where is it going? (Bob O. NJDEP)
A: Next step is to take another look at policy, not necessarily to do away with policy but
to improve upon it. EPA is going through a process to develop a report to give to
regions documenting the steps for implementation. We are collecting information,
looking at technical side of it and input from state programs. For immediate future we
see no change in independent applicability policy. (Margaret Stasikowski, EPA)
C: Report, in draft stage, is a comprehensive technical document seen as first step in
independent applicability policy. Evaluation of biological, chemical and WET
approaches - strengths and weaknesses, changes will proceed slowly and will be
science driven, only a technical document that describes where we are now. (Susan
Jackson, EPA)
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Q: What has been presented is great, but from a manager's point of view we are having
a problem just implementing chemical-specific toxics program. Sounds as if future
direction will be labor and resource intensive. Many states don't have the money. (Bob
O., NJDEP)
A: Look at resources. Basin-wide program does not have to be statewide; focus
resources on a few priority basins, as the program advances and achieves good results
hopefully more state funds will be applied to what seems worthwhile.
Q: How do you allocate responsibility or liability for nonpoint sources? How do you
handle the multiple natural stressors? How should we treat artificial ecosystems?
A: The approach allows us to put into perspective what the stressors are. If the primary
stressors are nonpoint sources, state it in the report and don't increase controls on
point sources. Be as specific as you can as to who is causing problems. NC does not
currently allow treatment in natural systems, but there are a lot of possibilities there.
(Tedder)
A: Identify pollution runoff source. Establish BMP program and define exactly what land
owner would be required to do. Take enforcement if they do not implement the
specified BMPs. (Landman) —
C: EPA is standing in the cart backwards, sending a mixed message. Telling us that it is
time to move on, develop new tools and step toward basin specific management
without providing flexibility in current requirements, like holding on to policy of
independent applicability Recommend that EPA delete policy of independent
applicability. (Peter Ruffier, City of Eugene)
Q: Wouldn't it be most efficient to identify problems on a national basis and then focus
state and national resources?
A: Can't take problems faced out there and boil them down to a national program.
(Tedder)
A: We would be usurping state authority if we look at a problem on a national basis.
(Cynthia Dougherty)
Q: Based on experience, should EPA continue with independent applicability policy?
Should changes be recommended to independent applicability? Should changes be
limited to watershed or ecosystem? How do you deal with questions of national
consistency on the state level if changes take place? (Fritz Wagener, EPA Region 4)
A: There is more to national consistency than adopting standards. National consistency
doesn't have to be in standards. (Tedder)
A: Independent applicability should be changed. Regulated community should not be
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penalized if state chooses not to irifplement watershed approach or held hostage to
independent applicability until watershed approach is implemented. Implementation
of watershed approach is Federal and state decision, regulated community can't do
this. (Michael R.)
A: Not prepared to see a change in independent applicability. Need to examine the legs
of the stool to see if they are scientifically sound. Time to look at national standards
and make decisions on mixing zones and other parts of the process to make truly
consistent standards. (Landman)
Q: EPA is raising a lot of expectations with common sense initiative and watershed
approach that they will have a lot of say on what goes on in the watershed. There are
other EPA programs that will be affected, 106(b), 319 funding will need to be
revisited. Need strategy to define where the flexibility will be.
A: There is no guidance; these programs are just getting off the ground. Have put on the
table the common sense initiative.
Q: Who are the stakeholders and what are their exact roles? Stakeholders should be in
the room when decisions are made and plan is developed. All stakeholders should be
involved in a watershed decision. (DuPont)
A: NC wants stakeholders involvement but will base decisions on sound science. Doesn't
want emotions or the stakeholders to be able to sway the decision in a bad way.
Important to have citizen involvement to get additional information but citizens will not
have veto power over the plans, the management agency will still have ultimate say.
(Tedder)
A: Stakeholders should not just have to watch the process, they should be able to
participate. Science should drive the process but stakeholders' ideas should be
included. (Michael Ruszcyk, Kodak)
A: There must be a bottom line at which point a baseline of protection is met. Local
stakeholders should not be able to set just any level of protection. Enlist a community
in investing in water protection by allowing them to participate. It is a delicate
balance. (Landman)
A: May not be able to have all stakeholders represented, may not be able to have a
representative group. In order to get balanced stakeholder involvement we try to get
them to provide suggestions as to what policy decisions to make. (Cynthia Dougherty)
Q: Since we are looking at watershed approach, shouldn't we be looking at regional
standards or site-specific standards and not national standards?
A: In great lakes area we have seen regional standards do not work because the areas are
so diverse, different ecosystems within the region. We may need watershed basin
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standards. (Tedder)
Water Quality Criteria and Standards Conference
Q: When is a watershed too large?
A: We already had a hierarchy in NC that divided the watersheds. They may not be too
big, may break up the watershed into smaller groups with different management
practices. (Tedder)
A: EPA may have answered this by developing ecoregions. These regions were developed
based on ecological conditions including aquatic and land biota. Hierarchy within
watershed, can't look at regions, can make observation and group together some
regions that are similar. (Tetratech)
A: Arkansas has had regional based standards for 10 years. Ecoregions are based on soil.
type, land use, and topography. This made a difference in the dissolved oxygen
standards. (Martin May)
A: For human health criteria, don't see an alternative to national criteria. For nutrients
and aquatic life criteria may be appropriate on a watershed basis. Right now we are
adjusting these criteria based on species sensitivity and hardness of water, etc.
(Margaret Stasikowski, EPA)
Q: Some people have suggested that we should delete policy of independent applicability.
Yet NC has flourished with a basin approach with independent applicability. How have
you dealt with independent applicability, multiple grant authorities? Identify what are
some of the hurdles to your development of a program. (Rob Wood, EPA)
A: Have never said that independent applicability is in our way. Trying to get away from
tunnel vision on where the funds are coming from. Want to put together some of the
grants like 305(b) and 319 and get rid of 305(b) reporting every 2 years. Can't
evaluate trends on a two year basis. How about a report every 5 years? Consolidate
reporting requirements so that more resources can be put toward program. (Tedder)
Q: Can you see any changes to the program that should be used?
A: Lack of trust among one another. Improvement - National Estuary Programs.
Stakeholders have been brought together. Bringing together stakeholders all over the
government on water quality. Need better database to make decisions on, like national
toxics database. (Landman)
Q: Watersheds do not obey state boundaries. How does NC deal with this issue?
A: NC management strategies are only implementable in our state. Working with
Tennessee and other states to develop plans together. At least share information.
(Tedder)
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C: Watershed approach is a good way to coordinate water quality standards programs
amongst tribes and adjoining states. We need to have the information upfront in order
to make decisions that are not in conflict. (Marsha H., EPA Region 10)
Q: Does NRDC support common sense initiative? (Bob Weaver)
A: Who could be against smarter, cheaper water protection? Participating, but do not
know what to expect. (Landman)
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Ad Hoc Session
TMDLS And The
Watershed Protection
Approach
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
TMDLS AND THE WATERSHED PROTECTION APPROACH
Russ Kinnerson
OST, EPA
Washimgton, DC
Don Brady
Watershed Branch
Office of Wetlands, Oceans and Watersheds
U.S. Environmental Protection Agency
Washington, DC
Co-Moderator
Co-Moderator
SUMMARY
What is a TMDL - sum of allowable WLAs (point sources) + LAs (nonpoint sources) + Margin
of Safety (MOS)
Why are TMDLs important?
quantifies loading capacity of a waterbody for a stressor
allocates allowable loadings among contributors
Primary characteristics
address unattained water quality standard on specific waterbodies
can be developed to address a significant stressor or multi-stressors
are quantitative
contain a margin of safety
are supported by the best available scientific information
TMDLS AND THE WATERSHED PROTECTION APPROACH
Dale Bryson
Director, Water Division
U.S. EPA, Reg/on 5
Chicago, IL
SUMMARY
History of TMDLs
started focusing on point sources
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Session 4 {Ad Hoc)
nonpoint sources were next
other factors to be addressed today
What is problem with approach of Federal/state programs
TMDLs think too narrowly
we focus on point sources
we don't understand nonpoint sources
Problems emerging
sediment
agricultural runoff
Superfund sites
RCRA sites
air deposition
bioaccumulative problems
Two planes to TMDLs
look at waste load from point source (this is usually easy)
looking at complex situation as tied to watershed approach (more difficult)
In planning for sink situations (ex. GLI, Chesapeake, Mississippi River) we must use the
complex TMDL approach
look at problems and where they originate
look at all nonpoint sources
look at entire watershed, not just 2 or 3 miles downstream of industries
force other people to come to table, e.g., Superfund, RCRA, Air
all sources end up in water therefore they must be involved
develop management plan for basin
Management plan vision
Use TMDL in process as base but must include several things:
sequence of events as we clean up water bodies
role of other media - Superfund, Air, RCRA
must have accountability
time-frame to revisit and assess progress
Phased approach to TMDLs needed when:
nonpoint sources
cross-media sources are involved
financial limitations exist
Phased TMDL does not mean point sources now and nonpoint sources later
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Phased TMDL does mean:
look at what is expected to meet standards
monitoring
revisiting problems
schedule for progression
Summary
Convince Congress that reasonable and steady progress is acceptable
Get help from other media programs
Focus on bioaccumulative compounds as a special category that doesn't need TMDL process
but that we have to get out of the environment now. The bioaccumulative compounds are
there and we need to deal with them now.
What is a complete water program? Watershed approach must focus on basics - monitoring,
permits, etc.
TMDLS AND THE WATERSHED PROTECTION APPROACH
Geoffrey H. Grubbs
Director, Office of Assessment
and Watershed Protection Division
Office of Wetlands, Oceans and Watersheds
U.S. Environmental Protection Agency
Washington, DC
SUMMARY
First lawsuit against EPA over TMDLs was in Michigan in 1987.
TMDLs has progressed a long way.
TMDLs can be a link between what the watershed is and what we can do.
TMDLs are the technical backbone of watershed protection
Four key aspects of TMDL process
geographic focus (place-based)
integrated action for all sources and stressors
stakeholder involvement
evaluate success
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Geographic focus of TMDL process
identifies impaired or threatened watersheds or bodies
forces clear focus on specific area
lends focus on priority problems, e.g., specific stressors
Interpreted action
identify significant sources and contributors
analyze combined impacts/effects of sources
consider broad array of social, economic and legal factors; this is a step that EPA can
help states with
recommends appropriate reductions
Stakeholder involvement
identifies stakeholders
provides a forum for discussion and analysis
provides content for agreement
implementation and continuing discussion
Evaluate success
long-term focus on established endpoints
phased approach is important due to technology limits, economics and other factors
Future and current directions for TMDL program
Don't see TMDL as a required step for every stressor in every waterbody, not enough
funding
Growing interest in non-chemical stressors - Oregon studies on temperature and forest
canopy
Will increasingly rely on nonpoint source control - USDA is a valuable source for
information on problems with nonpoint source pollution
Increased public involvement
Watch legal issues - TMDLs are open to lawsuits
Hierarchy on types of TMDLs
Watershed approach is here to stay, must keep focus on real measurable goals
Questions to audience:
How do you list impaired waters?
What do we really do about unsolved problems, e.g., PCBs in sediments?
How do we take stigma away from naming names? How do we get people to recognize
problems and solve them?
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SESSION 4: Ad Hoc (TMDLs) - Questions and Answers
Q: How does anti-backsliding affect this watershed approach? Basin has high natural
phosphorous but how high was not known until after TMDLs were set. Now the
POTW is stuck with these limits. TMDLs should not be set until all factors are
considered. (John Jackson)
A:
Q:
A:
Q:
A:
Q:
A:
A:
Can't generalize on site-specific conditions (Dale Bryson)
Regarding identifying impaired water body, as EPA develops new criteria (e.g.
sediment) what does this mean for the process? (Sharon Green)
In states where standards are already in place we'll be going with what the states say.
How can the process address areas where growth is occurring?
We will have to maintain standards and build in certain play for potential growth. This
is also an area where schedules can be implemented to allow compliance with
standards. Must look at the site specific conditions. TMDLs are normally targets
about how much loadings can be placed into a water body without exceeding the
standards. Many times TMDLs are then placed into permits. (Geoffrey Grubbs)
Could you comment on working with soil conservation in TMDL process?
Through TMDLs we are giving people credit for what they are already doing and
possibly requiring additional steps. Soil Conservation Districts can play an important
role in this TMDL process. (Geoffrey Grubbs)
We need reauthorization of CWA to give us some strength to deal with agricultural
runoff and other nonpoint source issues. (Dale Bryson)
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Ad Hoc Session
Implementing The
Endangered Species
Act
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IMPLEMENTING THE ENDANGERED SPECIES ACT
David Sabock
Health and Ecological Criteria Division
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
Moderator
AQUATIC ECOSYSTEM PROTECTION THROUGH THE ENDANGERED
SPECIES ACT
John Christian
Assistant Regional Director
Fisheries and Federal Aid
U.S. Fish and Wildlife Service
Ft. Snelling, MN
Abstract: This presentation will summarize the requirements of the Endangered Species Act
and outline water quality factors which lead to the endangerment of aquatic species. The
author will explain why current water quality standards and criteria may not be adequate to
protect some endangered species and why additional compliance with the Endangered Species
Act may be necessary. The principal recommendations and conclusions of the author are: 1)
to conclude that listed and threatened and endangered species are still being impacted by
water quality concerns; 2) to conclude that for the most part existing water quality criteria
and standards are beneficial for Endangered Species; 3) to recommend that additional analysis
is needed to identify any unique or specific water quality requirements for endangered species;
4) to recommend a collaborative and cooperative process between EPA, the States, and the
Service to develop water quality criteria and standards that are fully protective of listed
species; 5) to recommend that specific procedures be adopted to ensure appropriate
compliance with the Endangered Species Act and; 6) to recommend that an ecosystem
approach is the preferred method to avoid or minimize the application of any of the regulatory
provisions of the Endangered Species Act.
The best way to start this presentation is to read an excerpt from a recent New York Times
article entitled: "Water-based Animals are Becoming Extinct Faster than Others".
"Fish and other animals that live in North American waterways are disappearing much faster
than land-based fauna, survey data indicate. And without broad measures to protect water-
dependent creatures from such threats as pollution,...the rate of aquatic extinctions is likely
to accelerate...Indeed, while few were looking, many aquatic species recently disappeared,
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sometimes leaving gaping holes in the food chain and always diminishing forever the biological
diversity that keeps the earth genetically healthy..."
Lets take a look at the trends of aquatic species versus birds and mammals. According to the
Nature Conservancy, 7% of US mammals and birds are extinct or imperiled compared to 20%
of fishes, 55% of freshwater mussels and 36% of crayfish being-extinct or imperiled.
Also note that only 4%of listed aquatic species have shown signs of recovery.
Lets look at fish specifically. This status report was compiled by the American Fisheries
Society for all of North America. The data include State and Foreign sources as well species
listed under the US Endangered Species Act. Of 1,061 species of native freshwater fishes in
north America, 364 species are listed as endangered, threatened or are of special concern and
40 species are extinct; 16 since 1964.
The primary documented cause for these declines is the widespread degradation of aquatic
habitats.
Not all of this dismal picture is due to pollution, but a significant portion is. This slide is based
on American Fisheries Society data and it shows the factors behind the extinction of 40
species of North American fishes in the last century. The percentages for all the categories
add up to more than 100% because its believed that more than one factor is responsible for
each extinction.
But water pollution is identified as a factor in 38% of the extinctions.
Based on the documented declines of species and loss of biodiversity the Congress passed
the Endangered Species Act of 1973. It has been amended numerous times since then but
it remain substantially the same. The Act embodies a fairly comprehensive approach to
maintaining species diversity in the United States.
You might be asking yourself at this point : Okay, so we are losing species, so what!! The
dinosaurs went extinct and we're doing great without them!!!
Right. And the people in the movie Jurassic Park would no doubt agree!!
But endangered species do have values to society which led to our elected representatives
passing the Endangered Species Act. What are those values?
Here's 10 to think about:
1. Endangered species are an integral part of our nation's heritage. Their very existence is
part of our country's history and should be preserved.
2. Endangered species are our environmental barometers -"or canaries in the coal mine"-
warning us of environmental situations that could affect us.
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Water Quality Criteria and Standards Conference
3. Endangered species have utilitarian value for a range of human enterprises such as
agriculture, medicine, hunting, fishing, and wildlife watching.
4. Endangered species have scientific value. We can learn much about the life that sustains
us by studying endangered species in their habitats.
5. Endangered species have spiritual and aesthetic value for some . They are, for many
people, a source of personal and emotional fulfillment, appreciated for their beauty or
complexity or rarity.
6. Endangered species have intrinsic value for some people.
to exist is respected.
Meaning that the simple right
7. Endangered species have value for the survival of other species with which they are
interconnected (including humans). They have evolutionary value, in the contribution they
make to the global gene pool.
8. Endangered species have educational value. The plight of these organisms can raise public
awareness about the nature of environmental problems. And success in saving one species
can serve as a model for strategies that would save others.
9. Endangered species have value by virtue of their legal status. They are a legal force for
conservation and protection of our natural environment.
10. Endangered species are the "bottom line" reminder that the continued health of the planet
depends on the wisdom of our stewardship and that we have an ethical responsibility to
protect and conserve nature of which we are a part.
Maybe just as important as the above reasons is that your children care about endangered
species. Go home tonight and ask them if you don't believe me!!
Does everyone believe that the benefits of preventing the extinction of a species are worth
the cost to society? No. Hardly. Look at the Spotted Owl controversy. This situation and
others like it have lead to a great National debate as the U.S. Congress considers the
reauthorization of the Endangered Species Act.
Now for the quick review of the Act. If you want a lot of detail, I'll disappoint you. My
objective here is to give you a quick overview of the structure of the Act and the tools that
it contains to accomplish its purposes so you can put the other panel presentations in
perspective. If you want the details—you will need to read the Act.
I will focus my summary on the primary sections of the Act that relate to Purpose, Listing,
Recovery, Consultation and Protection.
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Section 2 -- Findings, Purposes, and Policy
The Act finds that human activities have caused the extinction of some species and put the
survival of other species at risk, that these species are of value, that the United States has
committed itself through several treaties to the conservation of species, and then states its
purpose very clearly:— the maintenance of endangered and threatened species and the
ecosystems upon which they depend.
Section 4 -- Listing and Recovery
Basic to the conservation of species at risk of extinction is a process for determining those
species in need of attention. Changes to the threatened and endangered species list are
accomplished through a rulemaking process involving proposal, public comment, and adoption
of a final rule.
There are 5 criteria for determining whether a species qualifies for listing. The criteria are: 1)
habitat loss, 2) direct taking, 3) disease, 4) inadequacy of existing regulatory mechanisms and
5) other natural or manmade factors.
The Act provides that the Secretary shall make listing decisions "solely on the basis of the
best scientific and commercial data available . . ." In other words, no economic or social
impact data may be used in making a listing decision.
When a species is placed on the list, section 4 requires that the agency specify, "to the
maximum extent prudent and determinable", the species' critical habitat. A designation of
critical habitat adds additional regulatory review requirements—but does not mean that
human activities are outlawed—which is a common fallacy!
Once a species is listed, a variety of protective measures become available, including the
requirement that a recovery plan be prepared for any listed species likely to benefit from the
effort.
A recovery plan establishes recovery goals and objectives, as well as an implementation
schedule and estimate of costs. Plans are also required to be subjected to public review
before being adopted or revised.
Obviously, once a species is recovered and removed from the list then the regulatory
provisions of the Act no longer apply.
Section 7 -- Consultation
One of the most important and controversial provisions of the Act is section 7,
Section 7(a){1) directs agencies to carry out programs for the conservation of endangered and
threatened species and Section 7(a)(2) requires them to ensure that the actions they
authorize, fund, or implement are not likely to jeopardize the continued existence of listed
species or to destroy or adversely modify critical habitat.
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Water Quality Criteria and Standards Conference
To comply with these provisions, agencies must consult with the Fish and Wildlife Service or
National Marine Fisheries Service on actions that may affect listed species or critical habitat.
;
To be more to the point in terms of the focus of this conference, we believe that EPA must
consult on water quality criteria, water quality standards and NPDES programs and permits.
In most cases consultation results in a no adverse affect determination with some beneficial
conservation recommendations. However, in a few cases consultation leads to a written
biological opinion as to whether the action is likely to jeopardize listed species or adversely
modify critical habitat. If the conclusion is "jeopardy" then reasonable and prudent
alternatives are provided that would avoid jeopardy if implemented.
The opinion must also document any expected taking of a species incidental to the action and
prescribe means to minimize impacts. An incidental take statement in the opinion defines
allowable take levels that remain after appropriate mitigation and in that regard protects
agencies against application of the take provisions of the Act under Section 9..
Section 7 also contains an elaborate but little-used process that allows a Cabinet-level
committee to exempt an agency's action from the duty to avoid jeopardy to a species or
adverse modification of critical habitat. This is the only part of the Act that provides for
explicit balancing between the survival of a species and the economic and social cost of its
conservation. It has been rarely used and most decisions have favored the species.
Section 9 -- Prohibitions
Section 9 of the Act prohibits "taking" of endangered animals. Taking is broadly defined to
include not only killing or wounding, but "harming and harassing." Taking of endangered plant
species is prohibited in some circumstances and not in others.
Section 10 — Permits
Permits can be issued that allow taking to carry out research or recovery activities.
Permits can also be issued to allow taking to occur on private lands provided there is
replacement. This "habitat conservation plan" permit mechanism has been useful in a number
of cases for easing the conflict between endangered species conservation and private
development activities.
Section 11— Penalties and enforcement
This section sets the penalties for violations of the Act, including civil fines up to $25,000 and
criminal penalties that may include fines up to $50,000, and imprisonment for up to 1 year.
Vehicles, vessels, and other equipment involved in a violation may also be subject to seizure.
That's the end of my summary. The overall structure of the Act is relatively simple—
provisions to list species in trouble, recover them and protect them from further threats to
extinction in the interim.
4-29
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Session 4 (Ad Hoc)
But as someone once said: "the devil is in the details"!!! If you want to examine the details
I would urge you to read the Act and its implementing regulations.
There are some that believe the Act stops progress in a significant way.
I will not agree with that.
In the vast majority of circumstances projects or other Federal actions are found to have no
adverse affect on species or only minor modifications needed. But the few major conflicts end
up on the front page of the newspapers and help form the public perceptions of the Act.
Heres the facts:
During the 6-year period from 1987 to 1992 there were over 94,000 informal consultations.
Only 2,700 (or 2.9%) resulted in the need for a formal consultation. Of the 2700 formals,
only 356 resulted in a jeopardy opinion (or 13%). Of the 356 jeopardy opinions only 54 (or
2%) ultimately blocked, cancelled, or terminated a Federal action. Over the 6 year period,
that represents an average of 9 per year. In a number of those cases the Federal agency
willingly withdraws the action realizing the project will lead to the extinction of a species.
So 99.94% of the projects reviewed under Section 7 of the Act went forward.
I therefore argue strongly that the Endangered Species Act is not the major impediment to
progress that some would like us to believe. Does it create additional workloads for agencies?
Yes. Does it increase project costs? In some cases, yes. Are the costs worth the benefits of
maintaining unique forms of life on this planet and the environmental underpinnings for us
humans?
The Congress has continued to say yes.
Is our administration of the Act perfect in every way? No. Hardly. But we are constantly
looking for ways to improve and are developing initiatives aimed at streamlining the
requirements of the Act and reducing economic impact while increasing species protection.
A number of these improvements have recently been announced by the White House and
cover such areas as increased peer review of Service proposals, avoiding crisis management
through cooperative approaches that focus on groups of species dependent on the same
ecosystem and increased participation of State agencies in Endangered Species Act activities.
These and other internal efforts will lead to improved administration of the Endangered
Species Act.
But what about EPA's programs and specifically, water quality criteria and standards in
relation to the provisions of the Endangered Species Act?
There has been a long standing presumption that EPA's programs only benefit and never harm
4-30
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
threatened and endangered species and that they contribute substantially to the recovery of
them. While we agree that this is generally the case, in a number of circumstances we believe
that EPA criteria. State water quality standards and NPDES permits either could result in harm
to species by not being sufficiently protective or are not contributing to their recovery.
I know those are fighting words to some—and we have been engaging in some of that over
the past few years with EPA and the States over compliance with Endangered Species Act
provisions. But all are realizing that there is some truth to this and that incremental actions
by EPA, the State water quality agencies and dischargers can both protect the survival of
listed species and lead to their recovery.
But I want to say for the record that the Fish and Wildlife Service recognizes the tremendous
progress made to date in pollution control by the EPA>. States and dischargers. And I want
to say that the vast majority of these regulated activities, do indeed, benefit species and their
ecosystems. But some fine tuning is necessary. The consultation provisions under Section 7
and the recovery provisions provide the mechanism for the fine tuning.
Water quality criteria and standards have been developed using, for the most part, a traditional
approach based on water column impacts of a chronic or acute nature to test organisms,
primarily fish.
In general, criteria and standards may not adequately protect some listed species in the
following circumstances: 1) migratory species blocked by mixing zones or other chemical or
physical blocks, 2) sedimentation that covers up fish eggs and smothers native mollusks, 3)
contamination of such sediments, 4) secondary impacts of bioaccumulation of toxics in
aquatic species that affect listed terrestrial wildlife that feed on them, 5) unfavorable flow
conditions for aquatic species either from water withdrawals, irrigation return flow or
industrial or municipal sources, 6) unique sensitivities of certain species that are lower than
EPA's standard test species or 7) some other unique site specific life history requirements of
a species.
I offer two simple approaches to modify State water quality standards where aquatic listed
species are present in a waterbody and have unique requirements that are not covered by the
existing standards or criteria.
One approach is to designate a beneficial use of threatened and endangered species protection
and then define any site specific criteria necessary to cover any unique needs. I have seen this
used in a few State standards. A second approach is to designate such segments as
Outstanding National Resource Waters and apply the more stringent prohibitions that go with
this designation.
How do we get consideration of endangered species in EPA and State water quality
management programs? I offer three recommendations.
First, we need to begin to talk to each other. That's essential. The ideal approach is to
develop collaborative efforts that are ecosystem based to protect species—in advance of the
4-31
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Session 4 {Ad Hoc)
need for listing, if possible. The regulated community also needs to be involved and can
contribute much to the dialog.
The Fish and Wildlife Service is actively implementing a new way of doing business based on
an ecosystem approach. EPA is also actively pursing a watershed approach with its partners.
These efforts need to be better integrated and coordinated.
Second, we believe that the recovery and consultation provisions of the Endangered Species
Act need to be applied to all Clean Water Act activities to create a framework for the
consideration of the unique needs of some listed species,.
And third, when Endangered Species Act conflicts do occur, the parties need to commit to
collaborative, interest based negotiation—and move from WIN/LOSE or LOSE/LOSE
Interaction models to WIN/WIN models. Yes— that comment includes all involved parties—
the Fish and Wildlife Service, EPA, the States and the regulated community!!!
Will there be problems?
Yes, particularly in the beginning as we try to understand each others authorities and integrate
our regulatory cultures and work out the details of interacting. And that has been true in the
development of a Memorandum of Agreement that Mike McGee will now be talking about.
However, if we stay focused on the goals of incrementally providing species protection while
keeping paperwork to a minimum, streamlining the process and seeking to minimize economic
impacts, we can succeed.
I think the ultimate result will be worth it. But it will require the commitment of all parties,
and liberal doses of common sense, trust and mutual respect.
4-32
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
AN ALTERNATE VIEW ON THE ENDANGERED SPECIES ACT AND ERA'S
WATER QUALITY CRITERIA DEVELOPMENT AND STANDARDS
APPROVAL
Robert F. (Mike) McGhee
Acting Director
Water Management Division
U.S. EPA, Region 4
Atlanta, GA
Duncan M. Powell
Endangered Species Act Coordinator
Water Management Division
U.S. EPA, Region 4
Atlanta, GA
Abstract: An integrated national committee, with representatives from the Department of
Interior's Fish and Wildlife Service, Department of Commerce's National Marine Fisheries
Service and the U.S. Environmental Protection Agency/Office of Water staff, investigated
development of procedures which would streamline and make more efficient use of inter-
agency relationships for EPA's federal actions, involving development of water quality criteria
and approval of state water quality standards. A draft Memorandum of Agreement was
developed by this committee. Three unique ideas were conceptually developed to meet the
requirements of the ESA for these two federal actions. These ideas included: (1) EPA's
development of draft biological evaluations for national water quality guidance values of two
chemicals, (2) the Services' development of draft biological opinions on these two chemicals,
and (3) procedures for the Services' review of state water quality standards.
4-33
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AIM ALTERNATIVE VIEW ON THE ESA & EPA'S WQC & S APPROVAL
Robert F. McGhee
Director, Water Management Division
U.S. EPA Region IV
Atlanta, GA
Interagency Task Force
EPA, FWS & NMFS
BASED ON JULY 24, 1992 MOA
Task Force Draft, Principle Agency Review, Agency Legal Review, Agency Staff
Review, Agency Review of Staff Comments, Signature Level Review
ft****************************
Endangered Species Act
as amended. Section 7(2)
"Each Federal Agencyshall, in consultation with and with the assistance of the Secretary,
insure that any action authorized, funded or carried out by such agency (an "agency action")
is not likely to jeopardize the continued existence of any endangered or threatened species of
result in the destruction or adverse modification of critical habitat..."
*****************************
Draft MOA regarding the ESA and CWA
Sections 303(c), 304)a), 402, and 405
EPA Agency Actions:
4 WATER QUALITY CRITERIA 4
4 WATER QUALITY STANDARDS 4
4NPDES PERMITS PROGRAMS*
**#**#**********»****#***#*****
"BENEFITS*
+ + + Agency Resources + + +
*Reduces Process Conflicts
*Focus Efforts for Maximum Coverage
*Provide National Consistency
* Reduces Litigation Activities
##*#*#**#*#**»##*##**##»»»»»»»*
•BENEFITS*
+ + + Natural Resources+ + +
* Identifies Resources at Greatest Risk
* Protect!on From Impacts
* Provides for Species Recovery
*****#******#*******************
-------
+ WATER QUALITY CRITERIA •
fit-
Development of New Water Quality Criteria
Methodological Guidelines
*>.
Consultation on Existing Criteria
Guidance Values
<*'
Development of New Section 304{a)
Criteria Guidance Values
#
EPA Headquarters Lead
at****************************
4 WATER QUALITY STANDARDS 4
<*
Development of New or Revised State
Water Quality Standards
<*
EPA Regional Offices Lead
*****************************
* NPDES PERMITS PROGRAMS *
Approval and Modification of State Programs
1 . Rulemaking
2. New State NPDES Program Applications
3. Existing NPDES State Programs
&
. Issuance of State NPDES Permits
#
Issuance of EPA NPDES Permits
(Including Sludge Provisions)
<*
EPA Regional Offices Lead
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
IMPLEMENTING THE ENDANGERED SPECIES ACT
Robert J. Smith
Competitive Enterprise Institute
Washington, DC
SUMMARY
ESA is a complete failure
has done more to jeopardize species than any other initiative
introduce you to adverse reaction against the ESA around the country
mostly in the pacific northwest
What is the act doing for incentives for private land owners?
Act is single most powerful act that has been promulgated to date
Directs all federal activities
Private landowner cannot do anything on his land that will "take" an endangered species
$100,000 for each taking and up to one year in jail
Nobody pays you for the loss of the use of your land
No just compensation
Creating a solid backlash against the protection of animals
Several unforeseeable court decisions on taking of bears have caused land owners to
implement the 3S syndrome-shoot, shovel and shut up
In southeastern US, timber owner, famous in conservation circles, turned land into wildlife
management. Managed part of the land to hunt bobwhite quail as well as protect
endangered redcocaked woodpecker. Now he cannot cut trees. He is losing money.
The act, by harming land owners and not providing compensation has driven these people to
destroy habitat. FWS needs to change to the Act to allow for the protection of
landowners rights
John Christian's Response:
Anecdote is a powerful tool. He has laid out the worst case to prove his point.
Admits he has seen some instances where the act implemented unjustly for individuals.
Will not admit that ESA is detrimental to wildlife and harms land owners. There are provisions
in the act for landowners. Section 10a - private landowners can develop habitat conservation
plan. If activity will result in loss of habitat can replace with habitat elsewhere.
Is there room for improvement in the Act? Yes. How do we integrate and resolve
these practices? There are positive examples and successful accommodations when dealing
with landowners.
4-35
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Session 4 (Ad Hoc)
Robert Smith Rebuttal:
Before ESA, had long tradition of voluntary conservation. These worked well even
without compensation. There is a lack of mutual respect between FWS and private land
owners.
4-36
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
SESSION 4: Ad Hoc (ESA) - Questions and Answers
Q:
A:
Q:
A:
A:
A:
Q:
A:
Q:
A:
Mary Joe Garreis owns land on lower eastern shore. Was going to put up stands to
promote nesting of eagles. They were approached by two hunting clubs who asked
her not to do it because it might affect their hunting. If habitat owner puts in a
conservation plan and the species flourishes, would land owner eventually have to
revisit plan or would they need to move out?
/
Region 4 - Bruce Babbitt announced that a deal is a deal. If conservation plan is
implemented would not be revisited. However, most plans allow for some taking
Robert: What happens with a new species come in after implementation of a well
thought out plan. Babbitt says well then you're in trouble.
What is trigger for state issued permits?
What about in standards process?
What is federal action requiring need for Section 7 consultation?
Reg 4 - Consultation has been done for a standard, if standard, reissued or No change
there is no consultation needed. If new information may revisit and then a
consultation would be required.
EPA feels state-issued permits not covered under ESA because it is not a federal
activity because if going to wipe out species, probably protected under the CWA
anyway.
Sabock: EPA approval of standards may be considered EPA criteria - published on
Then when applied on state standards and in permits consultation may be limited
Riverside County EA: People are better there. People are doing.
Important to remember that these people are not against the environment.
Need to address this in the reauthorization of ESA
Incentives are real important and just compensation.
Sabock: ESA up for reauthorization.
If non-delegated state do they have to consult on Section 7?
If EPA issued permit, will consult.
Is consulting at FWS Field Office?
Sabock: This is a reflection of the fact that the activities are occurring in the regional
office and information on species and effects to species are in the FWS field office.
4-37
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Session 4 (Ad Hoc)
A: John: See potential for conflict. Therefore regional review and implementation
provision. There is some degree of oversight built into MOU.
Q: Beth McGee - N.C. - Wildlife Resource Agency
What have you done on the National level for protection of species?
A: Region 4: Haven't addressed ESA on a national level.
A: John: In the case of non-point source pollution, incentive approach can be applied to
program that would be somewhat satisfactory to private land owners. Now need to
apply this type of approach to ESA.
A: On 319 grants one of selective factors is whether or not these activities will be
effective.
A: Dave Sabock:
EPA: 17 informal consultations underway
1 formal consultation underway
4-38
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I
Ad Hoc Session
Assessing Toxicity in
Sediment and Fish
1
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
ASSESSING AND REPORTING TOXICS IN SEDIMENT AND FISH
TOOLS FOR ENVIRONMENTAL MANAGERS AND DECISION-MAKERS
Thomas M. Armitage
Acting Chief
Risk Assessment and Management Branch
Standards and Applied Science Division, OST
U.S. Environmental Protection Agency
Washington, DC
Moderator
Abstract: EPA has developed national guidance for assessing the risks of consuming
chemically contaminated fish. The Agency is also developing national databases describing
the extent and severity of sediment and fish tissue contamination. These databases are now
being evaluated to produce the first biennial report to Congress on sediment quality in the
United States. This session will provide an overview of the new risk assessment guidance,
the national databases, and how they will be used by managers and decision-makers.
SUMMARY
Contaminated sediments
impact aquatic life
contribute to bioaccumulation
ecological effects
1980's EPA began to survey contaminated sediment toxicity
ecological impacts
health impacts
Findings indicated
important factors influence toxicity
grain size
organic carbon
Lack of information on these factors in previous studies indicates a need for
new data
EPA recently proposed an Agency-wide contaminated sediment strategy
Published in the Federal Register on August 31, 1994
EPA is developing national guidance for risk assessment on fish consumption advisory
State responsibility
4-39
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Session 4 (Ad Hoc)
No consistent approach
EPA is compiling a national fish tissue data repository
EPA is working on an inventory of contaminated sediment sites to target
- source control
- remediation
- prevention
4-40
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
THE NATIONAL SEDIMENT INVENTORY: A TOOL FOR
ENVIRONMENTAL MANAGERS AND DECISION-MAKERS
Catherine A. Fox
Environmental Scientist
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
Abstract: EPA is nearing completion of a four-year national study to assess the nature,
extent, and causes of sediment contamination in the United States. Data collected during the
study are being compiled in EPA's National Sediment Inventory. EPA program offices will use
the information in the National Sediment Inventory database to target sites for management
action including: monitoring, pollution prevention, source control, and dredged material
management. As a requirement of the Water Resource Development Act of 1992, EPA will
also continue to update and use the National Sediment Inventory to prepare a biennial Report
to Congress on sediment quality in the United States. This presentation provides an overview
of the types of information contained in the National Sediment Inventory, and a discussion of
the methodology used to evaluate the data. The presentation also describes the results of a
preliminary evaluation of the sediment chemistry and point-source release data contained in
the database to identify areas, chemicals, and industries of concern for the nation's aquatic
ecosystems.
SUMMARY
Purpose of National Sediment Inventory is:
To support development of National Sediment Strategy, Programs and Regions have already
provided OST with over 25 commitments on uses of data
Also through the Water Resources Development Act, Congress directed EPA to:
Develop a Report to Congress on sediment quality
Provide 2 year updates
The report will include
Site inventory
Point source analysis - report due out soon
Compilation and Analysis of non-point source pollution
beginning with pesticide use and
atmospheric deposition data to be carried out FY95
EPA began with a pilot inventory
4-41
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Session 4 (Ad Hoc)
Limitations of data in inventory
little TOC & AVS
detection limits are sometimes higher than threshold value
limited biological data
Limited QA/QC data
lat/long. not verified
variations in objectives of studies collected
multiple sampling and analysis methodologies used
Results of preliminary evaluation
evaluate data on water body segments/reach level
identify areas with elevated concentrations of sediment contaminants
threshold values used were
allow regions to verify targeted sites and provide additional data
NOAA ER-M - metals
EPA EQP for nonionic organics
Washington State lowest AET for ionic organics
Problem chemicals were defined as those for which the 50th percentile of each contaminant
within each watershed exceeded the threshold
Chemicals of concern included
PCB
Chlordane
DDT
Along with others
Areas of concern were identified throughout the country
4-42
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
NATIONAL GUIDANCE FOR ASSESSING THE RISKS OF CONSUMING
CHEMICALLY CONTAMINATED FISH
Jeffrey D. Bigler
Fisheries Biologist
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
The Office of Science and Technology's (OST) Fish Contamination Program (FCP) provides
technical assistance and guidance to State, Federal, and Tribal agencies for assessing human
health risks associated with dietary exposure to chemically contaminated noncommercial
freshwater and estuarine fish and shellfish. Technical assistance provided by the FCP includes
the development of national databases and guidance documents for developing fish
consumption advisories. This presentation provides an overview of the FCP guidance for
assessing the risks of consuming chemically contaminated fish.
The FCP is producing guidance documents designed to provide the States, Tribes, and other
interested parties with a scientifically defensible, cost effective methodology for developing,
implementing, managing and communicating risk-based fish consumption advisories. All
guidance is developed in a cooperative fashion with the States, Tribes, industry and
environmental groups. The first volume of four guidance documents, titled Volume I: Fish
Sampling and Analysis, was released in September 1993. This volume provides
recommended methods for fish collection, sampling strategies, field collection procedures,
chemical analysis, and data management. The guidance also provides profiles of 24 chemicals
which have been identified as analytes of concern with respect to dietary exposure to
chemical contaminants in fish.- The second volume of the guidance series. Risk Assessment
and Fish Consumption Limits, was released in June 1994. It provides chemical specific fish
consumption limits for 24 analytes based on the amount and frequency of individual fish
consumption. Specific fish consumption limits and advice for the general population and
women of child-bearing age are provided. The third volume of the series. Risk Management,
is under development and scheduled for release in late 1994. This document will identify and
review management options and issues which should be considered in the development of fish
consumption advisories. Topics covered include: variations in consumption patterns, health
and nutritional benefits, cultural, societal and economic impacts, and options for limiting
consumption. The fourth volume in the series. Risk Communication is also under development
and scheduled for release in the fall of 1994. This document will address effective
communication of fish consumption advisories to targeted audiences.
The guidance series developed by EPA provides the necessary information for developing,
implementing, and communicating scientifically sound, cost effective risk based fish
consumption advisories.
4-43
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
ERA'S FISH TISSUE DATA REPOSITORY
William F. (Rick) Hoffmann
Environmental Scientist
Fish Contamination Section
Standards and Applied Science Division, OST
U.S. Environmental Protection Agency
Washington, DC
Abstract: A variety of federal, state, and private organizations currently collect data on
chemical contaminants in fish and shellfish tissues. New national guidance has been issued
by EPA on collection and analysis of fish tissue for development of fish consumption
advisories. One important use of fish tissue contaminant data is to evaluate the potential risks
to recreational and subsistence anglers from chemical contaminants. Although agencies could
perform more sophisticated analyses by comparing data from other sources, they are currently
unable to share data sets. National analyses are also difficult to perform because of
difficulties assessing the data and inconsistencies in data sets. In response to state and other
requests, EPA has begun to implement and maintain a national repository known as the
National Fish Tissue Data Repository (NFTDR). The NFTDR is a powerful system designed for
users with various levels of computer experience. It offers user-friendly menus, help screens,
and technical dictionaries that make retrieving data relatively easy. Users can also transfer
data to other software formats (i.e., SAS, ARC/lnfo, PC spreadsheet) for further analysis. In
addition, EPA provides documentation that describes the NFTDR system, its data structure
and reporting options. Technical assistance is provided to users of the system. The NFTDR,
a component of EPA's Ocean Data Evaluation System (ODES), is maintained on EPA's
mainframe at the National Computing Center in North Carolina.
Prior to FY94, EPA focused on establishing the NFTDR. In FY94, EPA is continuing with the
development and implementation of the NFTDR. Activities include: conducting training
workshops for states and other within each of the EPA Regions; developing an NFTDR
demonstration package; and creating a database utility to verify that minimum data elements
are maintained. EPA is also working with several states and other data collectors to test
several pilot data sets. The experience gained from the pilot tests will be used to develop a
data management policy and to identify further changes to the NFTDR. EPA will work with
states and other data collection groups to expand the NFTDR database.
4-45
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Session 4 (Ad Hoc)
SESSION 4: Ad Hoc (Assessing Toxicity) - Questions & Answers
Q: Any plans to improve quality of data?
A: Yes. Currently combing out questionable data.
Evaluating suitability of threshold values for some chemicals.
Q: Have you done any sensitivity analysis on assumptions?
A: Yes, but only for the point source study so far.
Q: What sort of review is report going to get?
A: Peer review.
So far, most comments on methodology
Q: Recognizing the importance of TOC and AVS, is USGS including these variables?
A: I believe so.
Q: Concerned data released may cause problem if misinterpreted by public, as happened
with toxic release inventory.
A: Data is categorized by quality and conclusions will take into account data limitation and
uncertanity. Hopefully will be used responsibly.
Q: Have you accounted for the effect of decreasing detection limits on calculation of 50th
percentile?
A: Good question, will look into it.
Q: How much of data was collected for purpose of identifying hot spots?
A: Varied.
Q: Will EPA develop a national strategy to address mercury emission?
A: We are holding a National forum on mercury in fish in New Orleans later this month.
Q: How much QA/QC info will be in data bases?
A: Will not continue to require same level QA/QC established for ODES. ODES set up for
301 (L) program ocean discharge. Minimum, NFTDR will have some automatic checks
looking for obvious omissions. Not sure at this point what level of QA/QC will be.
4-46
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Session 4 (Ad Hoc) Water Quality Criteria and Standards Conference
Q: Will EPA be developing national fish tissue criteria?
A: Fish consumption rates and fish tissue data are used in developing human health water
quality criteria.
Q: How does database handle analytes not detected?
A: Considering adding another field for inputting the detection level rather than choosing
to input either zero, 1/2 detection level, or the detection level.
Q: How, if at all, will you factor in use of different sample preparation methodology for
example, skin on/off, fillet, or whole fish?
A: We've added capability to input information on methodology.
Q: Will data base support fish advisories for all states?
A: No, but another one does.
Q: How long are trials for data base?
A: Hoping to evaluate in October.
4-47
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Ad Hoc Session
Monitoring To
Support The
Watershed Protection
Approach
1
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
MONITORING TO SUPPORT THE WATERSHED PROTECTION APPROACH
Elizabeth Fellows
Chief, Monitoring Branch
Assessment and Watershed Protection Division
Office of Wetlands, Oceans and Watersheds
U.S. Environmental Protection Agency
Washington, DC
Moderator
SUMMARY
The purpose of this session is to discuss water monitoring to support the watershed
approach.
•j
The theme is that to support watershed management~or indeed water management at any
level, we need data of known quality from multiple sources.
i^
This session will give a brief overview of framework of what is going on nationally and within
EPA to address the question of getting better monitoring and assessment and reporting.
The question is how can we do a better job of assessing progress towards our water resource
goals including the designated uses set in State water quality standards.
The Monitoring Branch at EPA compiles the State 305(b) reports into a biennial National Water
Quality Inventory Report to Congress. The 1992 report is out, 1994 report is being worked
on and will be out in 1995. A consistency workgroup of 22 States, 3 Tribes, EPA, and other
federal agencies are working on guidelines for the 1996 report. They would like to replace
the 2 year report with a linked series of 305(b) reports that would comprehensively report on
the nation's waters over a 6-year cycle. During the 6-year cycle, "all" waters would be
assessed but in a targeted way depending on the condition of and goals for the waters.
Framework for monitoring was presented. Times have changed so monitoring needs to
change; it hasn't yet.
Reasons why monitoring should change:
Watershed Approach
biological monitoring
Non-point Sources - difficult to deal with compared to point sources.
Use of CIS as a tool
You never have enough data, but you have to act and can't wait for it to be perfect.
4-49
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Session 4 (Ad Hoc)
Major steps in revitalized monitoring program:
1. Redesign of monitoring coverage - base monitoring program assessing all waters.
(Attachment 1)
2. Targeted monitoring according to the goals for and condition of the waters
(Attachment 2)
3. Twenty-one Indicators - provides order/structure to measure national goals and State
designated uses; provide skeleton to measure program effectiveness or compliance.
(Attachment 3a and 3b)
4. Work on comparable methods - EPA Environmental Monitoring Management Council
to address use of comparable methods within EPA; links to intergovernmental work.
5. Modernize data system - STORET is oldest and largest database around, modernize and
take advantage of off-the-shelf technologies, add increased biological and metadata
capacity.
6. Modernize reporting [i.e., 305{b)]- Reporting to include both States and Indian tribes.
An Intergovernmental Task Force on Monitoring (ITFM) was formed. It is a Federal-State-
Tribal task force on monitoring with 20 official members and greater than 140-150 members
on 8 workgroups. The ITFM is preparing final recommendations that are due out in January
1995.
Five types of monitoring are being addressed by ITFM:
status/trends
existing and emerging problems and risk-based ranking of them
monitoring for program design to fix problems
monitoring to evaluate program to determine if it's effective and
emergency response.
Since you do monitoring for different purposes, monitoring must be done differently.
Overall recommendation of the ITFM is to develop an integrated nationwide, voluntary
strategy. Voluntary was the only thing that raised people's concerns (i.e.,will it work it it's
voluntary?) Incentive is to get more data from others - especially important in a watershed
focus.
Strategy (depicted on overhead) includes:
indicators to measure nationwide goals and State designated uses
collaboration on all levels of monitoring Federal, State, Tribal, Regional, watershed,
local
performance based methods to get at comparable methods
volunteer monitoring
compliance monitoring
data storage and retrieval - USGS modernizing their data base and EPA
modernizing STORET
joint training
4-50
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
research needs
funding and
evaluation.
Strategy report (provided as handout) will be noticed in the Federal Register. Deadline for
comments December 1.
There will be a permanent National Monitoring Council responsible for guidelines and program
assessment. Implementation structure will include State and tribal teams and regional teams
where needed.
4-51
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
MONITORING TO SUPPORT THE WATERSHED PROTECTION APPROACH
James G. Home
Special Assistant to the Director
Office of Wastewater Management
U.S. Environmental Protection Agency
Washington, DC
SUMMARY
How notion of goals and indicators are being translated by EPA through the National Goals
project. This project involved working with stakeholders to obtain consensus on goals and
use goals as benchmark.
Purposes of National Goals project
Have EPA state a series of environmental goals for a 10-year period
Involve stakeholders
Develop indicators to measure progress against goals.
Intent is to move from imeasures of activity to measures of environmental effectiveness.
As part of this overall agency process. Office of Water drafting chapter on water goals.
Main agency goal areas are:
clean and healthy land resources
clean air and atmosphere
clean and healthy water resources and
multi-media objectives.
Office of Water is responsible for two major goals:
clean surface and ground water and safe drinking water.
Eight of the 21 Office of Water environmental indicators were identified to measure to portray
achievement of the EPA goals: designated use attainment, reduction of key pollutants,
groundwater ambient condition, loss of wetlands, biological health of waters, drinking water
standards violations, reduction of key contaminants causing such violations, and source water
protection.
Stakeholders were involved in the process, public meetings were held around the country.
These meetings were really brainstorm sessions. Input from these sessions was used to
develop chapter for overall agency report. Second round of meetings will be held to receive
comments on report (should begin mid to late Nov and conclude late Jan-early Feb). EPA will
assess input and make revisions to report. The EPA report will be finalized and published on
4-53
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Session 4 (Ad Hoc)
Earth Day April 1995.
You can have national goals and environmental indicators, but if you don't have adequate
monitoring programs with information from all sources that can be used in a consistent
manner, it doesn't mean anything.
There is a project to test the use of the environmental indicators at the state level. The
following states are willing to test use of the indicators and are participating in the project:AZ,
DE, GA, ME, MD, OH, SC, Wl.
QUESTIONS AND ANSWERS (end of speaker)
Q: What is current status of indicators? Will States use them? (Nature Conservancy)
A: Have asked States participating in project to look at Office of Water's long list of
indicators and identify what they are using and if they added any indicators.
Q: Canals are classified as navigable. Many canals are privately owned. Will operator be
responsible for monitoring?
A: That would be up to the State.
Q: Why didn't the list include states like VA, CA that lead in water quality issues?
A: The States were selected because they volunteered for the project and with help of
watermonitoring coordinators and Regional NPDES authorities. Many States included
in the project are on the leading edge in monitoring. No state that applied to be a pilot
was turned down.
4-54
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Session 4 (Ad Hoc)
Water Quality Criteria and Standards Conference
MONITORING TO SUPPORT THE WATERSHED PROTECTION APPROACH
Charles A. Kanetsky
Region Water Quality Monitoring Coordinator
U.S. Environmental Protection Agency
Region 3
Philadelphia, PA
SUMMARY
EPA Region 3 305{b) Consistency Issues:
Region 3 States use data from several monitoring programs to make determinations on use
support of CWA fishable/swimmable goals. These data include conventional (e.g.) DO, pH,
temperature), biological, and chemical parameters. States generally report this information
on a watershed basis. Problems of consistency become obvious a we try to merge
assessment information from a watershed that cross state lines.
All Region 3 States assess water quality data to determine aquatic life use support (fishable)
based mostly on conventional and biological parameters. All Region 3 States follow EPA's
guidance (% exceedence criteria) for conventional parameters. Although all of the States use
biological data in these assessments, very little information is presented in the 305(b) Reports
on exactly how the determination is made. For Toxics/chemical data, most States use best
professional judgement in their determinations. Although not specifically stated in the
guidance on toxic criteria. Two States did stipulate that they more favorably weigh the
biological data over the chemical data. We believe the general reasons why States do not
follow the guidance is that the EPA guidance is too stringent and that criteria are actually at
the level of detection for many parameters (e.g. metals) and the States do not have enough
confidence in data at the level of detection to make a determination on fishability.
The inconsistencies in the determination of swimmable use support are much more obvious.
Only two States in Region 3 follow EPA's guidance. As a result, comparison between states
vary dramatically. All Region 3 States have adopted EPA Criteria for bacteriological indicators.
However, some States have additional criteria. Maryland requires a sanitary survey to verify
a problem. Virginia uses an instantaneous maximum of 1000. West Virginia also applies best
professional judgement to determine if a waterbody is a threat to public health. Pennsylvania
chooses not to evaluate their waters for swimmability because of the limited number of
bacteria samples collected. They do report on State Park Beach closures.
Recommendations:
EPA needs to define how the States are making use support determinations using biological
data.
4-55
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Session 4 (Ad Hoc)
EPA needs to revisit independent application and its toxic guidance.
EPA needs to work with the States to utilize a more consistent approach in determining
swimmable use support.
AQUATIC LIFE USE SUPPORT
1994 RIVERS AND STREAMS
State
DE
DC
MD
PA
VA
WV
Partial
80 (10%)
0.2 (0.5%)
1766 (10%)
1956 (8%)
1420 (4%)
3323 (63%)
Not
100 (12%)
23 (65%)
98 (0.5%)
2691 (11%)
389 (1%)
592 (10%)
Criteria
EPA-CONV,BIO,TOX
EPA-CONV,BIO
EPA-CONV,BIO
EPA-CONV,BIO,TOX
EPA-CONV,BIO,TOX
EPA-CONV,BIO,TOX
1986 GOLD BOOK
FRESHWATER PRIMARY RECREATION INDICATOR
Enterococci
E. Coli
Mean
33
126
Single
Beach
61
235
Sample
MOD
89
298
Maximum
Light
108
406
Maximum
INFREQ
151
576
PRIMARY RECREATION USE SUPPORT
1994 RIVERS AND STREAMS
STATE
DE
DC
MD
PA
VA
WV (92)
PARTIAL
119 (15%)
0
0
N/A
546 (2%)
1 1 63 (23%)
NOT
624 (78%)
26.5 (96%)
2.5 (0%)
N/A
205 (0.5%)
463 (10%)
CRITERIA
EPA
EPA
SANITARY
CLOSURES
1000
BPJ
4-56
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Session 4 (Ad Hoc) Water Quality Criteria and Standards Conference
MONITORING TO SUPPORT THE WATERSHED PROTECTION APPROACH
Chris O. Yoder
Manager, Ecological Assessment Section
Division of Surface Water
Ohio Environmental Protection Agency
Columbus, OH
SUMMARY
Parameters for base stream monitoring will be discussed.
A lot revolves around monitoring ecological conditions. Different water bodies should be
monitored for different parameters that reflect the different designated uses.
Ohio's monitoring program has a resource intensive biomonitoring component. The State
instituted a permit fee program to provide funds for monitoring program. Ohio prioritizes
monitoring with a 10-year cycle for revisiting major streams and water bodies.
When Ohio prepares 305(b) report, they relate special actions with what they're seeing in
water body.
State goal is 75% full restoration of streams not meeting designated uses by year 2000. If
State maintains current progress, the goal won't be reached. Improving point sources will not
enable goal to be reached; they need to look at nonpoint sources.
More than half of the state is not reporting any impaired habitat. They have good stressor and
exposure information, but not good response indicators.
Mr. Yoder noted biocriteria initiative is needed to move forward; it brings along Watershed
Approach, integrated points, habitat assessment, biodiversity, cumulative effects.
QUESTIONS AND ANSWERS (at end of speaker)
Q: We have indicators for fresh water. Is there any work on indicators for coastal
estuaries? (NY City DEP)
A: We do have them for fresh water and will develop indicators for other water bodies.
Both the ITFM and EPA;s coastal program are working on this.
C: We need flexibility to use resources more effectively.
C: There is a change at EPA. A shift from bean counting to watershed approach. Money
should go where the problems are, but need resources for base programs such as
4-57
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Session 4 (Ad Hoc)
monitoring.
C: Region 6 is working on grant to streamline programs. States can list waterbodies that
need data for 106(b) dollars.
C: When going to holistic approach, go beyond testing water column. How are we going
to train people to look at habitat assessment, testing sediments? Right there are now
only 2 labs on the east coast qualified to do clean/ultra-clean methods.
C: Lab accreditation being worked on. It's a big issue in EPA's Environmental Monitoring
Management Council. There will be national lab accreditation conference in next few
months. This is a difficult issue for small municipalities; EPA hopes to get joint training
programs and to make training available to municipalities at reduced costs.
Q: We heard a lot about new programs, new testing. Where do we get the money? We
don't have the lab capability at State level and when we get data back, we're not sure
what it means. It's a mandated initiative with no funding.
C: Clean testing will cost six times more.
C: At one sampling location, several different agencies monitor the same parameters.
When will STORET be ready so we don't all have to have individual data systems or
perform duplicative sampling? (Metro Denver)
A: A STORET will be fully modernized in 1997, but a prototype of part of the system will
be available in November 1994. However, that will not alone solve the problems that
you have with 8 different agencies sampling.
4-58
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1 1
J L
Session 5
Managing Risk:
Limitations And Barriers
To Implementation
i r
- 1 - 1
-------
-------
Session 5
Water Quality Criteria and Standards for the 21st Century
SESSION 5 - MANAGING RISK: LIMITATIONS AND BARRIERS TO
IMPLEMENTATION
Session Moderator
Chris Zarba
Health and Ecological Criteria Division
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC
Abstract: This session covers how creative, well planned risk management strategies have
been successfully implemented in watersheds. Case studies will be used to show how risk
managers have used innovative approaches to solve problems within resource limitations. Of
particular interest is a discussion on barriers that were encountered and the successful
approaches that were adopted to overcome them.
NATURE CONSERVANCY BIORESERVE
Robert Paulson
Environmental Toxicologist
Bureau of Water Resources Management
Wisconsin Department of Natural Resources
Madison, Wl
SUMMARY
Lower Green Bay Basin
25-26 subbasins, 6,000 sq. miles
Lower Fox River out of Lake Winnebag
40 nautical miles
Lower Fox - Industrialized
Contaminants - PCBs, Dioxins, DDT, DDD, DDE, Mercury, lead
Point sources, NP sources
PCBs - Paper companies
Can link to effects in basin
Cross bills in herons and other birds
As part of EPA funded project modeled it
Mass Balance Models
14 million dollar study
5-1
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Session 5
55 experts brought in
sediment transport models, water column models
organic carbon model
eutrophication model
modeled Green Bay and Lower Fox
Green Bay food chain model, toxics model
34 soft sediment areas/deposits contribute
PCBs - some concentration greater than 50 PPM
Based on data developed:
Green Bay/Fox Rivers Mass Balance Management Scenarios
Fish tissue - human health fish advisory, need to get to
50 ppb would take about 100 years
based on unlimited consumption
30,000-50,000 kg of PCB in sediments of river and bay
Point sources are insignificant to problem
25 year, no action, management strategy is not acceptable to get to levels
Remedial Action Plan-RAP-Fox River Coalition
Model of regional cooperation
local governments, industry, municipalities, sewerage districts, DNR, COE, etc.
Goal: figure out how, when and how to pay for contaminant sediment remediation
Accomplishments:
crossed political and philosophical boundaries to form group with common goal
priority ranking of upstream sites
raised 650,000 for R1/F5 of four deposits
conducted compatibility survey of local engineering firms
developed public information strategy
collected/analyzed data for downstream modeling decisions
Ongoing Activities:
Prioritize deposits
Some Sediments could be hazardous waste
PRP - demonstration project partially funded by federal money
Deposit "A" demonstration
remove 18% of PCBs above defer dam
assure authority for alternate disposal under TSCA
build local cooperation
Fox/Wolf Initiative - basin wide
started by non-profit groups to address nutrient and suspended solids
control from nonpoint sources
5-2
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Figure 1.
Watersheds of Concern
in Fox-Wolf River Basin
(Watersheds Identified In Fox-Wolf Initiative)
I f :
/ Green /
'( Ra\/ I DOOR
MANITOWOC
Lake
Michigan
I ___ L -- _ --
SHEBOYGAN
Critical for Lake Winnebago
and Green Bay (12)
Local Resource Benefits (10)
Already Selected as Priority
Watershed Project (4)
lureau of Water Resources Management
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Session 5
Water Quality Criteria and Standards for the 21st Century
MILLTOWN RESERVOIR-CLARK FORK RIVER, MONTANA: A
COMPREHENSIVE ECOLOGICAL RISK ASSESSMENT PROJECT
Julie DalSoglio
Remedial Project Manager
Montana Operations Office
U.S. Environmental Protection Agency
Region 8
Helena, MT
Abstract: U.S, EPA initiated an innovative ecological risk assessment at the Milltown
Superfund Site in August 1989. The site is located in the Clark Fork River basin of Western
Montana, and consists of 80 river miles and an 820 acre wetlands. The focus of the risk
assessment is to identify and chronic impacts from contaminated sediments in these
environments. Lack of established sediment quality criteria, the extent of habitats at the site,
and anticipated complex sediment chemistry led to a unique laboratory and field based
approach for the risk assessment. Ecological and toxicological studies were conducted by a
team of government, university, and contractor scientists. This integrated risk assessment
will help determine remedial action for the reservoir and sets the basis for additional studies
within the basin.
SUMMARY
Approach is many times based on enforcement approach
Complex
over 120 river miles
consisted of largest superfund complex in US - 4 sites
main industry, copper and gold mining
Active 1880-1882, 100 million tons of waste discharged to creek
another complex - smelting site - 15 square miles
Milltown site
listed in 1982 because of ground water contamination
arsenic was at 10 times acceptable levels
after dealing with human health issue the focus shifted to an ecological one
risk assessment showed primary stressor in upper Clark fork basin was Milltown site
strategy driven by concern from town of Dussela - 5 miles down stream
fact that the wetlands environment is an artificial wetlands created by dam
stakeholders
problems
at start of project there was no EPA guidance to make ecological assessment
5-3
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Session 5
assessment team stayed current with EPA thinking,
and was on track when guidance did come out
Ecological concerns
trout populations down to below carrying capacity due to fish kills
subtle impacts on wetland ecology altered biological community structure
transfer of metals through food chain
factors affecting focus of risk assessment
complex habitats of rivers, wetlands
sediment
recommendations to overcoming barriers:
use EPA guidance as framework and adapt to meet your situation
realizations
one doesn't have to show that there is damage in order to list a site as
superfund, just that there is a causeway for potential damage
need to focus on entire watershed
moved from lab approach to lab and field approach
tiered approach to address problems
Objective of lab and field studies
investigate relationships between metal concentrations in sediments and
potential ecological effects
evaluate impacts to plants and animals
decrease uncertainty in risk
used USFWS, Oregon State, Clemson, University of Wyoming to help with lab and
field work to achieve objectives
5-4
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Session 5
Water Quality Criteria and Standards for the 21st Century
CHESAPEAKE BAY PROGRAM EXPERIENCE WITH NUTRIENT LOAD
ALLOCATIONS MANAGING RISK: LESSONS LEARNED AND
OVERCOMING BARRIERS
The Chesapeake Bay Program Experience with Nutrient Load Allocations
Ed Stigall
Chief, Technical Programs
Chesapeake Bay Program Office
U.S. Environmental Protection Agency
Region 3
Annapolis, MD
Abstract: The nitrogen and phosphorous load allocations for Chesapeake Bay will be
presented and discussed as a case study. The various barriers and information gaps that had
to be overcome will be discussed along with the processes that had to be followed to reach
consensus by all parties on the appropriateness of the resulting load cap. This will include
how environmental models were utilized to synthesize scientific knowledge and bring about
paradigm shifts.
SUMMARY
One of the first barriers facing the Chesapeake Bay Program or any environmental program
is to be able to clearly define and measure progress.
The Chesapeake Bay Program established a goal of 40% reduction in phosphorous and
nitrogen.
Quantified the base load
Identified the controllable load
Calculated 40 % of the controllable load
Set year 2000 loading cap
In developing this goal, the program had to consider both nonpoint sources and point sources.
We used a landscape driven land transport model (HPSF) to predict nonpoint source loads.
We also had to consider how growth will increase loadings.
The Chesapeake Bay Program is tracking and communicating progress
Phosphorous - Point source loadings have already been reduced by 40%, though
loadings may increase somewhat due to growth. Nonpoint source reductions have not met
5-5
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Session 5
goal yet as measured from co-financed initiatives run by state agencies. Actual NFS
reductions are probably higher when you consider potential reductions that are privately
financed.
Nitrogen - Less progress has been made in reaching both point source and
nonpoint source goals.
Benefits from nitrogen and phosphorous load reductions are measured by recovery of
submerged aquatic vegetation. Data on distribution of SAV is collected through areal surveys
and volunteer monitoring. SAV distribution is an index of habitat improvement for aquatic
species. Other indicators include benthos and fish population.
Another barrier is understanding science. Encounter diverse opinions on problems and causes.
In the Chesapeake Bay a three dimensional model shows that reducing nitrogen loadings in
the lower bay will improve dissolved oxygen and reduce anoxic conditions higher in the Bay
based on the circulation patterns of the Bay. The Chesapeake Bay is a stratified estuary with
a salt water wedge moving up the Bay. The bay is phosphorous limited above the Bay Bridge
and nitrogen limited from the Potomac River south. Anoxic conditions result from northward
transport via the saltwater wedge of decomposing phytoplankton. Algal blooms stimulated
by nitrogen enrichment below the Potomac, settle to the saltwater wedge during
decomposition and are transported north where decomposition depletes dissolved oxygen.
A third barrier encountered by the CBP is abatement and control with a voluntary program.
Obtaining nonpoint source and point source reductions required persuasive arguments and
strong, reliable data.
Barriers Ahead:
Financing an accelerated level of effort
Continued calibration of models with new data. Developing a biofeedback capacity in
the model because as we continue to restore habitat and replenish the standing stock of fish
and vegetation, we expect nutrient levels to be affected. We need to predict how much
nitrogen and phosphorous will the standing stock bind.
Talk briefly about some examples of regulatory controls used for nonpoint source control:
Sediment and erosion controls at construction sites are being implemented by states and
counties.
New developments are underway in controlling stormwater runoff
Urban stormwater is being controlled by NPDES permits
Evaluating possibility of using paragraph 6 of TSCA to make nutrients a 'prescription drug' so
5-6
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Session 5
Water Quality Criteria and Standards for the 21st Century
that before a large scale user can buy nutrients, he/she must have developed a management
plan. Pennsylvania already has a requirement of nutrient management and both Virginia and
Maryland have proposals before the state legislature.
We are also working with fertilizer manufacturers to replace their product recommendations
with regional recommendations from agricultural service. This will alter the recommended
timing of fertilizer application and greatly reduce runoff.
5-7
-------
-------
SETTING CAPS FOR NUTRIENT
LOADS
Chesapeake Bay Program Experience
in
Overcoming Barriers and Obstacles
-------
-------
BARRIERS WE HAVE OVERCOME
. Measuring Progress and Demonstrating the
Benefits
-------
CHESAPEAKE BAY BASIN
STRATEGY REDUCTION
(millions of pounds)
1985 Base Load
Controllable Load
40% of Controllable Load
Year 2000 Allocation Load (Cap)
Growth Increase Loadd 985-1 992)
Estimated 1 992 Load with Growth
1992 Progress Run Load(Model)
Reduction Progess-to-date(1992)
Growth Increase Loadd 993-2000)
Remaining Reduction
NITROGEN
304.1
185.5
74.2
229.9
14.6
318.7
288.1
30.6
16.6
74.8
PHOSPHOROUS
23.87
21.08
8.43
15.44
1.50
25.37
18.34
7.03
1.71
4.61
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BARRIERS WE HAVE OVERCOME
1. Measuring Progress and Demonstrating the
Benefits
2. Understanding the Science
-------
-------
BARRIERS WE HAVE OVERCOME
1. Measuring Progress and Demonstrating the
Benefits
2. Understanding the Science
3. Abatement and Control with a Voluntary Program
-------
BARRIERS WE HAVE OVERCOME
/. Measuring Progress and Demonstrating the
Benefits
2. Understanding the Science
3. Abatement and Control with a Voluntary
Program
BARRIERS STILL AHEAD
/. Financing an accelerated level of effort.
2. As we continue to restore habitat and replenish
standing stock of the fisheries will the nutrient
levels be affected?
-------
-------
Session 5
Water Quality Criteria and Standards for the 21st Century
NATURE CONSERVANCY BIORESERVE
W. William Weeks
Chief Operating Officer
The Nature Conservancy
Arlington, VA
SUMMARY
Ecosystem/Watershed Management
Nature Conservancy is moving towards protection of watersheds
process for applying limited resources for conservation problems
Goal of Conservancy
narrow issue = Protection of Biodiversity
limits focus of Nature Conservancy
Nature Conservancy interested in WQS/ criteria in relation to achieving stated goal
generally. Nature Conservancy working in "easier places" where life issues exist, not
remediation, but instead preservation
Focus - creation of habitat that is protected
process
identifying stresses
tracing stresses to sources (social and economic)
looking for things to measure
not concerned if "remote" risks
makes Nature Conservancy risk management "less cosmic"
not looking for ideal standard; focus on specific biological standard that will protect
stated goal
Goal of Planning Process of Nature Conservancy
not satisfied in "management" of risk
want to eliminate risk in watershed or conservation area
need to get people to table
unlike EPA, has no stick
ways to get people involved
provide new information
Ecological Processes
Nature Conservancy able to expand conservation strategies/objectives with growth of
organization
5-9
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Session 5
but must be careful not to address issues at too large a scale
picking too large a scale may limit effectiveness of program
may not be able to focus on most important aspect
local cooperation through education/information
Lessons on Watershed Management - Process
identify systems
decide what you want to accomplish
objectives are key
ecosystems may be too large to focus on
possibly better to pick smaller scale projects
prioritize actions, focus resources
key is careful identification of system/species
identify stresses (threat)
biological stress
source of stress
identify ways to modify stress activity to address biological threat
trace to source
develop strategies
must acknowledge legitimacy of other people's goals
must look at how to adjust activities to achieve goals
recognize everyone's objectives without destroying ecosystem protection
objective
goal - nonconfrontational activities/cooperation
decide what represents successes
don't focus on just carrying through activities
must set goal and measure
Result - Plan
Nature Conservancy has an advantage/plan is not public document
so can adjust plan along the way
organic document changing with experience
must move parties that appear to have different interests to a point where they
realize that consensus can be reached where environmental/conservation
goals can be achieved without unreasonably eliminating or ignoring the
interest of the persons undertaking activities
5-10
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Session 5
SESSION 5: QUESTIONS AND ANSWERS
Water Quality Criteria and Standards for the 21st Century
Q: Amoco. For Green Bay - Were you gathering a lot of fish tissue data? Who initiated
the project?
A: Bob: DNR We have a fish tissue monitoring program. Data collected was fed into
model.
Project just happened. Basin already has a RAP group but was broadened. DNR did
not facilitate it, came through the RAP process.
Q: Tennessee. For Chesapeake - Chesapeake is obvious candidate for degradation
process. Has this been considered?
A. Stigall: Approach it as a pollution prevention process. Have anti-degradation programs
but looking at survivorship of the land under a pollution prevention program. Looking
at effect of landscape from land uses. Not typical anti-degradation project.
Q: Are they harvesting vegetation in the Bay?
A: Stigall - No.
5-11
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Session 5 - Managing Risk: Group 1
Water Quality Criteria and Standards for the 21st Century
BREAKOUT GROUP DISCUSSIONS - GROUP 1
Robert Paulson Group Moderator
Environmental Toxicologist
Bureau of Water Resources Management
Wisconsin Department of Natural Resources
Madison, Wl
SUMMARY
Want perspectives on barriers and how we get around them in risk assessments
Inflexible regulations (State or Federal)
In Wisconsin public had to be educated
RAP got the word out
Came up with Green Bay Backer Award
School education program
Questions and Answers
Q: How did Wl come up with cost estimates for cost of Green Bay Project?
A: 14 Million dollars sponsored through EPA
RI/FS will look at the different deposits
Coalition will prioritize remediation and develop unit costs for the remediation
Looking at creative funding through cost sharing
Q: What is the time frame for Wl project?
A: 50 years
Q: Did people know or comprehend the size of this project before getting into it?
A: Yes
Q: Barrier: Money to deal with entire watershed
A: Based on costs sometimes it will be the deciding factor to just leave the sediments
there
Some may decide to settle for lesser goals and take a risk or put up dollars to do it.
5-13
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Session 5 - Managing Risk: Group 1
That is where the RAP comes into the decision.
Q: Look at getting PRP to pass costs on to create a disincentive for these things
happening in the future. If funding projects through government funds.
A: Needs some proactive approach to provide disincentives. Pollution prevention may be
a way to provide incentives.
Q: FWS have related problem in New York. They know the source but do not know what
to do with it.
PCBs are leaking and discharging into river
Inadequate standards process as to what constitutes a no discharge vs. no
detectible discharge.
Permits have 1200 ppt PCS limits
If you allow a discharge of this magnitude, you are going to have sediment
problems
Relates to several barriers:
Moving pollution around
Biologists vs. Engineers
Can't get engineers to implement BMPs because they think that they are unenforceable
and will not take the risk.
Request to EPA: Need better detection limits
A: Or other types of methods to regulate and use the data
There is a proposed protocol for bioconcentratable compounds
Q: Barrier: People want numbers
All consultants and PRP want a number. If too high, does not meet environmental
goals. If too low, will take it to court. Therefore need to be willing to do a watershed
assessment.
Q: Nondetect thinking and enforcing WQS and permits always have been a numerical
based program.
If EPA could push the mind set along for innovative criteria it would be helpful
A: Barrier Non-detect limits
5-14
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Session 5 - Managing Risk: Group 1
Water Quality Criteria and Standards for the 21st Century
Q: Detection limit always keep us from finding chemical concentrations that cause the
effects
Therefore we need to move toward biological indicators
A: Barriers: Non-effect criteria
Bio-indicators
Biosurveys
Q: In Wl what sort of barriers are you running into when you translate biological factors
into something meaningful for tax payers?
A: Fish consumption advisories are one of the biggest things.
Q: Have you estimated what it would cost to get rid of fish advisories?
Until you cost that you will still have a public barrier.
A: When we get it costed, it then becomes a social decision and negotiation?
Mass balance started in 1989
Coalition only 11/2 years old
Q: Do you feel you have PCBs under control?
A: From point sources.
Q: But not from other sources?
A: No
Decision is generally that it will be unacceptable to wait it out.
Q: Need an innovative way to get it out without remediating sediments.
A: Looking at solidification and in place solutions.
Q: Los Angeles sanitation- discharge to dry stream and marine waters.
Involved in watershed project
River is 90% owned privately
Discharge to dry streams and create the habitats
Stockholders (30 fed, state, local and privately owned)
Trust is major issue
5-15
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Session 5 - Managing Risk: Group 1
Private landholders have much bigger stake than government entity and remind them
of that.
This has created a lot of barriers
Study has been going on for 1 112 years already and using up resources fast.
Barrier: Conflicting uses of watershed. Some seem like they override one another
Barrier: Issue of technology with sediments
How many different statutes does Wl project fall under?
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
TSCA, NRDA action against five mills from FWS. NRDA brought a lot of people to
coalition.
Subject to great lakes legislation?
Yes guidance for remedial action in GL LAMP, Great Lakes Initiative which won't be
too disruptive to project because already incorporate many of the provisions into
existing rules.
Superfund?
Deposit A may have gone superfund or RCRA. Work with solid waste people in the
state.
Could go through EARP process if necessary. Better to just get the stuff out of the
river.
Do your POTW discharges in Wl have WET limits?
Yes since 1989. Mills have been meeting WET limits. Only one POTW not meeting
limits.
Acute and chronic limits based on flow
Numerical limits?
Must demonstrate that there is toxicity, then Wl requires quarterly monitoring
One failure would kick you into another test in 21 days
Put them into a TIE phase in some instances to avoid limits in the permit.
5-16
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Session 5 - Managing Risk: Group 1
Water Quality Criteria and Standards for the 21st Century
List of Barriers Developed in Break Out Session
Inflexible regulations (state and federal)
Public Involvement
Money to deal with entire watershed
Disincentives to prevent future problems
Knowing source but can't do anything about it
Multi-media transfer
Biologist vs. Engineers
Non-Detect limits
Trust (private landowners have biggest stake)
Conflicting uses
Technology for sediment cleanup
5-17
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-------
Session 5 - Managing Risk: Group 2
Water Quality Criteria and Standards for the 21st Century
BREAKOUT GROUP DISCUSSIONS - GROUP 2
Julie DalSoglio
Remedial Project Manager
Montana Operations Office
U.S. Environmental Protection Agency
Region 8
Helena, MT
Group Moderator
SUMMARY
Two most critical barriers in ecological risk assessment
lack of guidance
latter guidance validated direction
biological resource groups have been formed in each region
this is a helpful source that wasn't available at the beginning of the
process
lack of methodology
Primary question at Milltown - sediment toxicity
there was no standard methodology (EPA)
ISF&WS had developed some for Great Lakes and were interested in our
project
Questions and Answers
C: We are trying to come up with a way to decide on fish advisories for lead in fish
tissue. We don't have a standard for Pb. We are mainly working with EPA. We're
seeing more lead in sediments in macro invertebrates. It appears to biodilute rather
than bioaccumulate because we found more in vegetarian fish than in carnivorous. We
found more lead in fish bones than in muscles etc. (Jeff Harvey)
Moving standards - as standards decrease do we move to more stringent controls?
Q: One of the problems we have is using data from other regions which may not be
similar to your region. Example in Colorado is in selenium where most of the data is
from California. How are we going to integrate interquality and quantity when several
parties need to be coordinated? (Mark P.)
Julie. At Milltown we wanted to get away from labs and do site specific situations.
For example, in fish studies we did we used invertebrate food sources from the Clark
River. A problem with this is that it is extremely costly.
Water quality: It's not realistic to discuss quantity and quality as separate
5-19
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Session 5 - Managing Risk: Group 2
issues. The two are so closely related that we must consider both.
One example: Agency set up sediment ponds to improve water quality and are
being sued by public who claims the ponds allow for evaporation and therefore
is a take on their water rates.
Q: We don't hear much about work on WQC. Why is this? (Julie)
A: Cost is the number one factor and burden of proof is a close second. People perceive
the national standards as acceptable unless you can prove and educate people
otherwise.
Q: How do you tie risk base assessment to compliance. There are questions as to if the
correct regulation framework will even allow this. In addition, the public views this
approach as one that is trying to avoid standards.
C: Consultants are pricey.
Q: How are we going to transfer this costly process to the poor communities
(environmental justice).
Q: On-going issues of good labs and question of national accreditation.
A: We had a unique situation because we used universities etc. that saw our situation as
a good experience and therefore helped keep costs down. (Julie)
C: In response to having site specific standards this would get overburdensome. He is
trying to pool together areas with similar problems, such as coppers and using a similar
standard for all these sites. (Dianne Feed, N.C.)
C: Our state is unique because the majority of our problems are non-point source, so its
difficult to apply standards in a manner such as N.C. is doing. (Jeff Harvey)
C: One key barrier is an institutional barrier: science takes a long time and when an
agency tells the public they're working on something without issuing a time-frame the
public expects results soon. EPA develops standards and then walks away from them.
We have standards that are 20 years old and haven't been updated. (Jerry Patamos)
C: Superfund is talking about more stringent national standards which is moving away
from site-specific standards (Julie)
A: The idea behind this is to speed up the clean-up process. Site specific standards
require both time and money. Another barrier is the guidance to apply drinking water
standards to the aquifer as opposed to the tap. Many times it may be more effective
to treat water at the tap instead of at the source. In addition, some treatment is
required even if the source water meets the standards, this is required even though no
risk assessment has been conducted to establish a thread of any kind.
5-20
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Session 5 - Managing Risk: Group 3
Water Quality Criteria and Standards for the 21st Century
BREAKOUT GROUP DISCUSSIONS - GROUP 3
Ed Stigall
Chief, Technical Programs
Chesapeake Bay Program Office
U.S. Environmental Protection Agency
Region 3
Annapolis, MD
SUMMARY
Request input on barriers encountered by participants.
C: One barrier encountered in the Chesapeake Bay was funding. The approach taken was
to look around at other programs within the basin and identify ways that they could
contribute to the CBP. Numerous agencies and organizations contribute technical
assistance. Four federal agencies and one state provide staff to actually work in the
Chesapeake Bay Program Office.
C: Another barrier identified is statutory authority at the local level, including enabling
legislation, taxation authority, fee structure authority, and enforcement authority.
C: A barrier encountered in trying to implement nonpoint source controls is uniform
application of requirements for diverse sources. It is important for the credibility of the
program to be equitable across sources (e.g. construction, agriculture).
C: Establishing who gets to make decisions is sometimes a barrier to organizing a
watershed management team.
R: A tip from the Chesapeake Bay Program is to get negotiation and consensus building
training. Our program was designed to test/demonstrate a cooperative, non-command
approach to restoration.
C: Availability and ability to generate reliable data is another barrier.
C: Interagency coordination is another barrier.
Questions and Answers: The Chesapeake Bay Program
Q: Where did the 40 percent reduction in nutrient loadings come from?
A: Estimate of what the nonpoint source program could achieve without new technology
5-21
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Session 5 - Managing Risk: Group 3
or funding. Then we modeled the impact of achieving this goal on ecosystem
variables.
Q: How has the Chesapeake Bay communicated its message?
A: We have a number of mechanisms, including:
- Alliance for the Chesapeake Bay (grantee)
- Public Advisory Committee
- Citizen monitoring network
We are currently developing a program to train citizens on wetland designation.
Q: Who decided SAV should be an indicator?
A: Science and Technical Advisory Committee
Q: Do you attribute the return of SAV to progress in meeting the nutrient reduction goal?
A: Yes
Q: How much are chicken farms contributing to the nutrient loading in the Bay?
A: Poultry plants are using nutrient management practices to reduce loadings, including
dry clean-up of chicken coops, storage of manure until spring fertilizer applications, and
compost for disposal of dead chickens.
Q: Is groundwater a concern?
A: Most of the groundwater under the chicken farms violates nitrogen standards. We are
hoping to study groundwater transport and flushing.
Q: When and how did the Chesapeake Bay Program get organized?
A: The process started in 1977 as an EPA research project under Tudor Davis. Following
that study, the first Chesapeake Bay Agreement, signed in 1984, established the
executive council and committees. We have received strong public support from the
beginning.
Q: Was the early data on the Chesapeake Bay reliable?
A: Because bad data is worse than no data, we established groundrules on data quality.
Q: How did you get better data?
A: We have an extensive monitoring program that is model driven. All data collected
feeds into the model, we do not collect any superfluous data.
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Session 5 - Managing Risk: Group 3 Water Quality Criteria and Standards for the 21st Century
Q: How does the CBP maintain communication?
A: We work very closely with stakeholders and other government agencies. We also
maintain a directory of the Chesapeake Bay participants. We are also fortunate in that
one of the key stakeholders, created by the Chesapeake Bay Agreement, is the
Chesapeake Bay Commission. The Commission is composed of representatives from
all the state legislatures. They provide a quick entre to the legislature which has
proven invaluable in achieving timely solutions to critical problems.
Q: How did you estimate that the 40 (or 36) percent nutrient loadings were achievable?
A: Modeling
C: Looking at cost effectiveness analysis of BMPs.
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Session 5 - Managing Risk: Group 4
Water Quality Criteria and Standards for the 21st Century
BREAKOUT GROUP DISCUSSIONS - GROUP 4
W. William Weeks
Chief Operating Officer
The Nature Conservancy
Arlington, VA
Group Moderator
SUMMARY
Task - Identify Common Barriers To Risk Management On Watershed Basis
Problems in understanding what "Watershed Management" means.
disconnect between "resource" (rivers and streams) and permits
too much focus on procedural (permitting) issues rather than looking at biological
issues to determine appropriate management approaches
discussion has not focused on biological health of rivers/wetlands, but instead on
issuing permits to facilities in watershed
no overriding goal
restoration
fishable?/swimable?
Reverse process in issuing permits
need to change from "engineering" to "ecological" approach
permit writers mentality is that writing good permits will produce good water
quality
Moving to ecological approach
will create permit backlog
will create problems in permit issuance process, which involves extensive negotiation;
if watershed approach dictates specific permit limits, it will cause friction by
lack of flexibility
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Stakeholders
Session
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Water Quality Criteria and Standards for the 21st Century
SUMMARY AND CONCLUSIONS
Betsy Southerland
Director, Standards and Applied Science Division
Office of Science and Technology
U.S. EPA
Washington, DC
Moderator
We have assembled experts on the interests of tribes, state government, municipalities,
industry, and environmental groups. These five people have spent the past three days trying
to caucus with other conference participants so they could present a stakeholder opinion on
the implementation issues involved with all five of the conference sessions. However, each
of the stakeholders wants me to caution you that their comments will still reflect their
personal opinions and interpretation. They will do the best they can to reflect their
constituent groups.
The stakeholders listened to each session and then identified the implementation questions
that could be derived from the science discussions in those sessions.
We heard in Session I that some toxics reside in the water column and their effects are on
aquatic life. We knew that water quality criteria were needed to deal with those toxics. We
also heard presentations that said many toxicants reside in the sediments, accumulate up the
food chain and then cause problems for wildlife, or for human consumers of fish. We were
told you need sediment or fish tissue criteria for these toxicants. Most of us had experience
only with water quality criteria. We understood what was being done for acute and chronic
toxicity for aquatic life or the human health methodology for water quality criteria. We didn't
know what type of criteria to expect for new types of toxic chemical criteria based on
sediment or fish tissue concentrations. The first management question we asked was "Should
EPA put a higher priority on producing water quality criteria (with the methodology we were
all familiar with) and develop criteria for more toxicants which persist in the water column and
cause aquatic life effects?" Or, "Should EPA put a higher priority on developing
methodologies for the new type of criteria for bioaccumulative toxic pollutants?"
In Session I we heard that the National Research Council had recommended that EPA use a
default approach for toxics criteria. An EPA default value is derived from doing a risk
assessment, which will produce a range of values, and then making a risk management
decision in EPA as to what a single value or default value would be for that toxic chemical
criterion. The alternative approach would be for EPA to do the risk assessment, provide the
full range of values to the states and the tribes, and let the states and the tribes be
responsible for making the risk management decisions needed to adopt a single value
standard. Our second management question was "which type of criteria was preferable, the
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default or range of values criterion?"
In the second session we heard some excellent presentations on the different methods various
states had developed to look at non-toxic problems. These methods were for watershed
problems that were not related to chemical toxicants in the water column or the sediment.
instead, these problems involved nutrient enrichment, habitat degradation, sedimentation or
clean sediment problems, and flow alteration. For this session, we developed the following
management question, "Should EPA require states or tribes with flow problems, or clean
sediment problems, or enrichment problems, to use these kinds of methods to interpret their
narrative criterion. If so, EPA approval of the water quality standards program in some future
triennial review would depend on the state or tribe having adopted these methods to interpret
the narrative criterion. Or "Should EPA give out guidance and pilot studies on all the different
ways you can assess these problems and not require these methods to be included in water
quality standards programs.
In Session 3 we had a lot of discussion of ecological risk assessments and case studies. The
first two sessions were on appropriate criteria or methods for attacking watershed problems,
but session 3 was on how to go about identifying problems in a watershed. The management
or Implementation question we formulated was "What should EPA do to encourage the
conduct of ecological risk assessments in high priority watersheds?" We thought ecological
risk assessments were effective in determining whether chemical pollution, habitat alteration,
nutrient enrichment, or maybe all of the above were causing watershed problems.. We were
concerned about the expense of these assessments and questioned what EPA could do to
promote them.
Sessions 4 and 5 included case studies and examples of how to fix watershed problems. The
presenters identified what the problems were, selected the appropriate tools (whether they
were chemical criteria or non-chemical type approaches), and decided how to fix the
problems. Our management question was "Should EPA continue its independent applicability
policy in which all types of criteria must be met?" When we used the term criteria, we meant
chemical criteria as well as flow alteration, sedimentation, or nutrient methods. Some
stakeholders felt that there would be an incentive for States and tribes to use new methods
if they did not have to continue meeting the current chemical criteria.
Without any further ado, let me start with the first stakeholder. He is Daren Olsen. Daren
is in charge of the water quality standards program for the Nez Perce Tribe. He is located in
Lapwai, Idaho. His educational background is in watershed management.
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STAKEHOLDER OBSERVATIONS - Tribal Perspective
Darren Olsen
Nez Perce Tribe
Lapwai, Idaho
As Betsy said, I was supposed to coordinate with other tribal representatives that were here
at the conference. That was a tough assignment because I could not find any other tribal
representatives and that reflects the lack of resources that the tribes have in developing and
implementing standards for the reservations.
Question Number One: Should EPA put higher priority on producing water quality criteria for
pollutants or on developing methodologies for new types of criteria? I found this to be a
tricky question, in that EPA should invest in both producing criteria for more pollutants and
continue to develop methodologies for new types of criteria. It is my opinion that EPA criteria
plans should follow simple laws, such as the law of diminishing returns. Science can be
defined as the successive approximation of the truth. To me that means we may never get
to the total truth through science, and that we may never get the exact and perfect criteria
to protect the use. If I want to go up and touch this wall and every five minutes I get closer
to that wall, how long will it take to touch that wall. I won't get there in my lifetime and my
children's children's lifetime. But there is a certain point where I am close enough to that wall
to know the attributes of that wall.
The question is, when are we close enough to that criteria? To complete my answer, each
investment EPA makes need to be flexible, and they should stop worrying about the mice
when the elephants are trampling over them. EPA should concentrate on enforcement and
on helping the tribes and states to enforce what good criteria there are.
Question Number TWO: Should EPA develop criteria that consist of 1) a default based on risk
or single value assessment and risk management decisions, or 2) ranges of values on risk
assessment only. As a scientist, number two is clearly the correct answer. Ranges of value
can promote more flexibility in developing the most appropriate criteria. But in all practicality
the Nez Perce Tribe, and I might add some other tribes and states, do not have the resources
or mechanisms to develop site-specific criteria. Therefore, EPA should provide a default value.
But,, if resources are there, then I would lean more towards developing site-specific criteria
within a range.
From session number two, the first question was, "Should EPA require states to adopt
methods for nutrient over-enrichment, habitat degradation, sedimentation and flow alteration,
when appropriate, or leave this as a voluntary act by the states? It is my understanding that
under the Clean Water Act, EPA has responsibility to see that the Act's objectives are met.
If states are reluctant or dragging their feet toward adopting appropriate criteria, then it is the
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responsibility of EPA to see that states or tribes have the proper incentives and provide federal
funding for this task, and allow innovative strategies produced by the states and tribes to be
used to answer this complex issue.
Session number three, "What can EPA do to encourage the conduct of ecological risk
assessment in high priority watersheds?" To encourage ecological risk assessments, there
must be a modification and expansion of the scientific process for assessing risk at the
watershed level. And what I mean by the watershed level, should actually be called the
ecosystem level, especially when there are distinct ecosystems withjn the watersheds. And
they should continue to encourage all stakeholders within that watershed to participate
without reference to political boundaries with the cooperative mindset of all involved to
protect that use.
And finally, Session four, "Should EPA continue its independent applicability policy under
which all types of criteria must be met? I guess the purpose of me being here representative
of a stakeholder, is to give my perspective on these important questions and not just to make
friends. Therefore, with that behind me, I feel that EPA should absolutely continue its
independent applicability policy. All indicators of the system are measured independently, yet
are dependent upon each other. The opportunity to abuse this policy exists. Yet to protect
the biological, chemical and physical properties of our nation's waters requires that all three
type of criteria mut be met simutaneously. To conclude, I have a final comment. We have
talked very much at this conference about applying the watershed approach. The major
difference from states and tribes on this issue is that states are going through transition of
implementing a watershed approach through their existing water quality standard program.
Tribes are going through transition of developing and implementing water quality standards
through an already existing watershed approach in the way they manage land and overall way
of thinking for themselves. Both states and tribes should identify the abilities and limitations
of each other and concentrate on working through the jurisdictional issues to protect uses of
each water body.
Moderator: Our next speaker is Joel Cross, Manager of the Water Quality Management
Planning Section in Illinois' Division of Water Pollution Control. His group is responsible for
water quality standards, non-point source pollution, clean lakes and ambient monitoring. He
is located in Springfield, Illinois and his background is in aquatic biology.
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STAKEHOLDER OBSERVATIONS - State Perspective
Joel Cross
Manager, Water Quality Management Planning Section
Illinois Division of Water Pollution Control
I think in general, from the states point of view, there were some things that we heard at this
conference during the last three days that were very encouraging. Some of those things
included one-size-doesn't necessarily fit-all situations; factoring in common-sense decision-
making; integrating activities that are conducted by the regulatory agencies; and striving to
achieve well-balanced type program in stakeholder involvement. I will offer my views with
regard to the first management question dealing with a higher priority being placed on water
quality criteria for more pollutants or developing methods for new types of criteria. I think if
we are going to move toward more of an ecosystem approach, states are going to need more
tools and criteria. At same time we can't ignore producing additional water quality criteria.
At some point there has to be a balance that we have to strike based on available resources.
I think states would like to see U.S. EPA develop a regular schedule for developing new
criteria and reviewing current water quality criteria. States should not be required to adopt
all national criteria. States should have flexibility to adopt appropriate criteria where
necessary to achieve designated uses.
Question two involved whether a criterian should be a default value based on risk assessment
and risk management decisions or a range of values. In talking with a few states during the
conference, it seems that most favored the ranges of values, with guidance on selecting a
value for site-specific watersheds. That was from a very small sampling of states, so there
may be a large margin of error in that response. Regardless of the options that we choose,
I think this begins to address the issue of implementation of criteria. States recommend that
any new criteria published also include an implementation component that allows for state
input. I think as states we recognize the need for consistency with regard to the
implementation of criteria and standards.
Question three, "Should EPA require states states to adopt methods for nutrient over
enrichment, habitat degradation, sedimentation and flow alteration, wherever appropriate or
leave this as a voluntary act by the states? I think that most states believe this should remain
a voluntary activity for states. U.S. EPA should certainly encourage states to adopt methods
for these types of issues, including bio-criteria. EPA plays a vital role for providing technical
information and assistance, and I think that role should be contiued and enhanced. The key
word is require. Require seems to foster a top down approach, which doesn't promote
innovation and aggressive approaches to complex watershed problems, especially when
dealing with non-point source impact. I think that during the session, we heard several good
papers and presentations from states and from other people from all over the country, with
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good examples and approaches.
Question four, "What can EPA do to encourage the conduct of ecological risk assessments
for high priority watersheds?" I think there are many ways that EPA can do this. I'm just
going to focus on a couple that I think are important. Comprehensive ecological risk
assessments also need to be a voluntary objective for states, and that is strongly encouraged
by incentives that are meaningful to states. Promising more funds from sources which cannot
currently meet state needs provides no real incentive for states. The other issue that we
spent a considerable amount of time on in this morning's breakout session dealt with
removing barriers to implementing such an approach. I think EPA needs to continue to explore
more ways of removing barriers to consolidating program elements and should promote
integration, efficiency and effectiveness. For example, I think there are many examples of
programs, such as the 404 dredge and fill program, the 319 program, the 303D process for
listing impaired waters, the 305B process, all managed at the federal program in an isolated
manner at this point. Yet there are very important interactions among the requirements of
these programs. I don't think we can afford the luxury of continuing to devote separate
equipment, staff time and efforts to these things in an isolated program kind of approach. I
think integrating these programs would go a long way in encouraging states to begin to
address ecological risk assessments.
Question five, "Should EPA continue its independent applicability policy under which all types
of criteria must be met? I believe that we need to move beyond EPA's independent
applicability policy. It is far too limiting and doesn't allow states to make best decisions in
all cases. I don't think anyone would disagree that we need to use all tools and criteria where
available, but when you do have conflicts in where criteria are met, common-sense needs to
be factored into decision-making process. There is really no substitute for first-hand
knowledge of the resource and the data collected when looking at whether all criteria may be
applicable or appropriate. In conclusion, I would just like to say that states are obviously a
big player, not only in development of water quality standards, but in implementation as well.
It is important to remember that states have very elaborate and lengthy processes for
adopting state water quality standards, many times involving several years of effort. As
national criteria become more complex, and as more criteria are developed. States will be
faced with many more challenges, not only in getting water quality standards, but also in
creating an additional workload regarding implementation;;
And finally, I would like to thank U.S. EPA for hosting this conference. I think there were
some very interesting things that resulted from the conference during the last three days. I
would also like to thank them for the opportunity to provide the State's point of view.
Moderator: Our next speaker is Bob Berger. He is with the East Bay Municpal Utility District.
He is Manager of their regulatory planning and analysis group. They are located in San
Francisco Bay. A great place! His educational background is in marine biology and
biochemistry.
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Water Quality Criteria and Standards for the 21st Century
STAKEHOLDER OBSERVATIONS - Municipality Perspective
Robert Berger
East Bay Municipal Utility District
San Francisco, CA
Thank you. I would like to first thank Bill Kramer and Dave Sabock for giving me this
opportunity. I jumped at the chance, because unlike most of the participants in this
conference, I did not have to develop any materials, any audiovisual materials and I got a
chance to give my talk at the end. Unfortunately, like most of life, the reality differs from the
initial expectations. What it required me to do was sit through all the sessions, really pay
attention and stay to the very end of the thing. I think yesterday's session showed that there
was a real acceptance of the concepts that EPA is proposing to use as they go forward in
water quality standards into the 21st century, but there were very different expectations as
to how these concepts would be implemented. I think that is the key part, if we are going
to have effective environmental control, then there has to be the buy in and support of that
implementation by all the participating parties. I think the two themes I would like to have
included in my comments is that in addition to risk assessment, I think there is going to be
an element of risk taking in all of this, and certainly because I am a stakeholder, we would like
fuller participation by the stakeholders in the process.
My answers to the two criteria questions are kind of guided by my past experience as well
as some of the sentiments I heard here and agree with. I think unquestionably that we do
need to move forward with the kinds of measurement and control tools that will support
additional types of criteria. That's essential, in fact if we are going to have, and I think we
should have the comprehensive water quality based management that EPA is proposing. And
I think additional water quality criteria, as they are needed, also should be done. But I think
all these types of criteria have to be developed with certain key components. One of these
is they must be tied to implementation. That requires the development of necessary tools and
the application of all those tools in a comprehensive way. And a balanced application
between both point and non-point sources and across media, as we heard yesterday, about
air. What you have been hearing is that a toolbox does exist. However, what we as
regulated parties, as permit holders, and by in large what's in there right now are hammers.
What we would like to see more screw drivers and perhaps some pliers that can be applied
to everyone.
The second thought is it must be iterative. It must be based on good science and it must
reflect always reflect the best and most up to date science. I think that is one of the failings
of the water quality standards program, if you are looking at the chemicals. A lot of those
were developed probably 13 years ago on information that was developed even prior to that.
they have not been reviewed and evaluated in a comprehensive way by EPA, either looking
at the methodology or the data acceptability, a well as the individual values. They are going
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to continue to play a major role in watershed management, and do have to be reviewed. But
that should be applied to all the standards. And thirdly, they must be linked to relevant
performance measures. That's going to get you the buy-in. While it may be easy to say, yes
we are making progress because we are either above or below the chemical criteria, that really
doesn't speak to whether the designated uses are being protected.
With regard to the second question, I think a range of values is the most appropriate. The
states should be allowed the flexibility to accommodate what is now called place-based
influences to make the standards most relevant to specific sites. And I would suggest as part
of risk taking that flexibility for states should go even further so that the standard numeric
value may be looked at differently. I'm not advocating narrative values, but what I am
advocating is relevant values. Instead of a specific chemical concentration, we really could
use bio-mass as a goal and criterion.
Moving on to non-toxic problems. I think it is important that EPA set expectations. Maybe
not requirements, because I think as we move into these new programs it's going to require
the buy-in of the particular stakeholders. The top down command and control approach is not
going to be as effective now, and EPA's programs are going to be thought of as our programs.
What EPA's got to do is develop nationally consistent expectations, which include
environmental goals, the general programs to address these goals, and general progress in
meeting the goals. Yes, I think requirements or incentives are necessary so that not only do
states have the incentives to move forward, but they have the political coverage in justifying
the needs not only to their legislatures, but to some of the people they will be regulating with
these new tools.
With regard to ecological assessment, again the most effective way of having that performed
is to present it as our program, not EPA's program, since this comprehensive asessment
requires communication and involvement with stakeholders. We've seen that in previous talks
on this panel and earlier panels. I think we have to build the confidence of the stakeholders
in the process. We need to develop goals that are relevant and accepted. We need to have
good measurement and control tools available now or the implementation of this, and they
have to have certain criteria. They have to be scientifically valid. They have to be somewhat
proven, and they have to be able to be comprehensively applied. I think we also have to
provide clear and realistic expectations for the evolution of the water quality standards
program. The program plan needs to include time-frames, and the general elements of the
program. It needs to identify the incentives and disencentives that are going to be used to
accomplish it. And again, first and foremost it needs real involvement of all stakeholders at
all steps of the process.
With regard to independent applicability. Well, we've been through this a number of times.
When EPA first brought this up two years ago, I thought the message was farily clearly sent
at that time, that that is the way we were going. I don't think enough was heard in that
hiatus, in that two years hiatus. I hope they have clearly heard today and during this
conference that if, in fact you were going to put forth the kinds of programs that this is, the
only way you can get it accomplished. And as part of that, perhaps I should just suggest,
that they don't wait to get stakeholders involved, that they get them involved in the review
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Water Quality Criteria and Standards for the 21st Century
process. It has been my experience, not only with EPA but with any bureaucracy that the
greater refinement always constitutes greater ownership and the cement starts hardening on
that document. We need to get involved now. And the second part of it is, we know we're
not there yet, because the tools aren't there yet. In order for us to have a good evaluation,
we are not throwing away all of the measurements, we're simply going to make all of them
available when we make our comprehensive decision, and so that requires that a number of
the tools be better developed than they are today.
I would like to close by suggesting a few things that may in fact facilitate the process. I think
one of the things that may in fact facilitate the proces. I think one of the things that needs
to be done and was brought out yesterday, is that EPA needs to organize a meeting that now
really gets into what the water strategy is. I was kind of surprised in fact there is no clearly
defined strategy on EPA's part to take us this far. What we have done I think at this
conference is to name where we are going with these things. We've got the concepts out
there, and we need to now start establishing a more consistent expectation of what those
concepts mean to us before we move ahead. And that's got to happen soon and it has to
involve all the stakeholders. And by all the stakeholders we are missing right now, I believe
certainly the landowners, the farmers. We have to be encouraged to start contending this,
because if in fact we intend to make them partners, they have to be aware and if not certainly
enthusiastic about this, very aware of our determination to include them in this.
Again, I think we need to define common expectations, goals of the process, the general goals
of this thing, obviously they are going to change, based on where they're implemented, but
there needs to be an amount of minimal consistency throughout the nation on it. "Time-
frames, responsibilities and impediments.
The second thing as I said before is to develop the proper and appropriate meaurement and
control tools that can be universally applied to all sources and stresses of pollution. The third
thing that needs to be done is to reevaluate the current water criteria. That is going to be
essential, not only for the current program, but because the criteria are the basis for
watershed risk assessment as well. And a lot of this we need, the risk taking. Most of my
experience has been in the hand wringing stages with a lot of EPA personnel and state
personnel wanting to do non-point source controls, but not feeling they could go forward
without the mandate of the Clean Water Act. I think that the presentations from Ohio, Idaho,
South Florida, North Carolina, Chesapeake Bay, and Wisconsin show that people are willing
to take those risks, that they are proceeding without legal mandates on this stuff, and are
being successful. I think we need to get out the story on that and encourage more.
And fourth, to allow us the flexibility to be taking the kind of risk that we are going to need,
we do need to pursue legislation. And I think we need to be pursuing it, maybe by joining
hands. Maybe this is the first area that we get into as stakeholders. I didn't hear anybody
say that non-point sources should not be controlled in some way. That did not happen this
time. What we need to do is form an an alliance that can go to Congress and that says "yes,"
we represent the regulated municipalities, regulated industries, the States and environmental
advocates, and we may not agree on all of it, but here are a couple of issues that we do agree
on. I think that's how we have to get that flexibility in it, but again we are not always going
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to have that. I think we have to provide a little bit of risk taking for this.
Moderator: Our next speaker is Mary Buzby who represents Merck and Company
pharmaceutical. She's in charge of water programs at Merck and Company. She's located
at White House Station in New Jersey. And her backgound is in environmental science.
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Water Quality Criteria and Standards for the 21st Century
STAKEHOLDER OBERVATIONS - Industry Perspective
Mary Buzby
Merck and Company, Inc.
White House Station, New Jersey
Hello, I'm very happy to be here today, and I do want to thank my associates from other
industrial representatives that are here. We talked about this and these ideas are shared
among us. Before I start answering the questions, I thought I'd start by summarizing
industry's perspective on some of the issues discussed here over the last few days. That
should that make it easier to understand what our thinking is all about. First of all, industry
heartily endorses the concept of the watershed management approach to water quality
protection. In some cases the current water program fails to address ecosystem degradation,
while the water quality standards are met, and other cases there is no apparent degradation
but there are requirements to go further in reducing concentrations of certain compounds to
meet numerical limits.
So second of all, we think that successful implementation of the watershed requires equal
participation by all parties. Industry certainly wants to be at the table. We very much
appreciate the opportunity to be here, and we want to contribute to the protection and the
restoration of watersheds throughout the nation. We think we have some expertise, and we
would like to see the large amount of money I'll talk about later, the money that we've spent
on the environment, invested in real solutions to real problems. We agree that all stakeholders
should come to the table in good faith. It was stated that this process would only work, if
it's a process based on trust. We are committed to come to the table in good faith, to be
consensus builders and to be objective in identifying the goals in correcting water quality
problems, and implementing practices to achieve those goals.
A third basic issue or concept is that it's important for us to leverage our resources. Again
we heard discussion about this throughout the meeting. We have to get to the point where
we are investing our resources to achieve the best environmental benefit. Yesterday I was
at one of the breakout sessions, and I heard discussions by one state representative that said
that 72% of that state's water budget is spent on administration, NPDES implementation and
construction grants program. Those three aspects of the water quality program consume
70% of the money that is available in that state. And clearly at the meeting that was
supposed to be typical among the states. And that amount of money is disproportionate to
the needs that were identified at the conference. For example, industry is very proud of the
progress that the country, and that industry has made, along with EPA and the states under
the NPDES program. However, it may be time for EPA to reevaluate the NPDES program to
decide how this program can be developed into an asset to support the watershed approach
to water quality management and to achieve our other nationwide water quality goals. The
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NPDES program should not remain as a competing program, competing for resources and
recognition in our water quality management efforts.
Our resources need to be spent developing meaningful data. Not necessarily convenient data,
not necessarily easy data, but we have to get the data we need to make the correct
management decisions. We have to solve real problems, not perceptions of problems. A true
understanding of our ecosystem and it's magnificent diversity must be the basis of our
decisions, and we can only make those decisions if we have the right data.
I think that many of you will be surprised at how much money industry spends complying with
environmental regulations. Some of that money is not wisely invested. Industry would much
rather invest in addressing real problems. Presently we generate reams of data, a lot of it is
only for compliance and doesn't add value to the environment. An example of how we can
use our money better, it was clear yesterday in a poster presentation by Amoco. Amoco
joined in a joint venture with EPA to evaluate alternatives to regulated environmental
practices. Here is an example where they had a requirement to control some systems under
the regulation, they were required to control 3.4 tons per year of benzene and 170 tons of
hydrocarbons at the cost of $31 million. As a result of this joint project with EPA, they
demonstrated that an alternative would achieve much higher levels of pollutant reductions at
a significant cost savings. And I think more and more we have to be doing this kind of
approach to environmental management and environmental protection.
They also at the same time looked at a multi-media approach and found that they could
remove 7,200 tons of BOCs for $54 million which is the required process, the mandated
regulation and as an alternative that came up with little more emissions reductions for
significant more savings. Now if the difference of those values were invested, now this is
tons of money, this amount of money can make a big difference in the water quality program
in a state. We need more flexibility in the regulatory process.
The fourth issue that we think is required, is there has to be an implementation strategy for
watershed management that is flexible, that involves voluntary actions to achieve goals, and
that moves away from the traditional stance of command and control. That is our basic
philosophy. And now to answer the questions.
The first question was, Should EPA put a higher priority on producing water quality criteria
for more pollutants or developing methodologies for new types of criteria. Our response is
quite strong. Rather than put our resources into more numerical criteria, EPA should focus
its high priority on developing new tools, new methodologies to define stresses in the
environment. What we need are models, ways to link stresses to sources and to receptors,
for example, biocriteria, and diversity indexes that could be broadly applied with guidance by
EPA. in all cases, tools that are developed should be used by EPA and groups appropriately
for individual situations. Many of us in the industrial community have had experiences where
we have invested lots of effort and lots of energy in complying with numerical criteria which
we knew were not problems with the environment. On the other hand, if there is a problem
with numerical criteria, there is a need for numerical criteria, EPA should certainly go ahead
and develop those. It's just that the development of numerical criteria should not stand in the
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way of development of new, more progressive tools that there is clear a need for.
The second question. Should EPA develop criteria that consists of a default value based on
risk assessment and decisions, QT_ ranges of values based on risk assessment only. Our
answer is that there should be a range of values. A range of values is more flexible and
allows for risk management decisions that reflect local needs, local opportunities and that are
more appropriate for local communities. One thing I should say about the form of these
questions is that both of these questions on session I are that should we do this, or should
we do that. I think the tone of this conference it's been clear that whether should we do this,
or that, we should recognize that there are a range of opportunities, a range of methods that
can be implemented to improve the water environment and that we should not restrict any
of them, and that we should use every opportunity we have to do the right thing. J
The question from session two was, Should EPA require states to adopt methods for nutrient
enrichment and habitat degradation and sedimentation or should they leave these methods to
states for a voluntary practice. And we think that EPA should provide guidance, true
guidance, goals and expectations to states and others on what methodologies are appropriate
to address water quality issues. EPA and its research and development function has a broad
charter to develop technical and scientifically-based guidance. States should be in a position
to decide how to implement the guidance, and decide on what guidance should be
implemented to achieve their goals. And when I say the states, I mean in fact the states, and
the stakeholders involved in the watershed under consideration.
And the third session was about. What can EPA do to encourage ecological risk assessment
in high priority waters? We think that for EPA to encourage ecological risk assessments they
have to back off from the command and control posture. Command and control is
fundamentally in conflict with the concepts we have heard at the meeting, with the concepts
we have heard from those who have been successful in developing watershed management
plans. EPA should continue modeling efforts, so that we can create tools that are useful to
water managers in assessing risks. One thing I think we have to keep in mind that we have
to allow time, we frequently get tied up in statutory mandates and in regulatory schedules
that are unrealistic. We have to know what is real, what is possible, what's the most
important and act in an ordered fashion to take care of the biggest problems first rather than
tie us up in knots by coming up with unrealistic schedules and unrealistic expectations.
Also, in order for EPA to encourage ecological risk assessments, EPA should take very
seriously, the question of education and the responsibility EPA has to educate all stakeholders.
Frequently, especially individual citizens, are victims of fear, and they shouldn't live in fear.
These are problems we can deal with, these are problems we can understand, these are
problems we can learn about and the citizens deserve to know they are not victims of random
poisoning. In fact, they should know we can address the contamination problems and protect
everyone's well-being, including that of their ecosystems. We think that all participants
should know what is going on in the water systems and understand what the impacts of
individual citizens are, what the impacts of groups are on water quality. EPA should
encourage the assessment of ecological risks, nourish the spirit of trust, and encourage an
understanding of all points of view.
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And finally, our sixth question. Should EPA continue its independent applicability policy that
all types of criteria should be met? We say no. Independent applicability is counter-
productive to fostering a watershed approach to water quality. EPA must go beyond
command and control. They must rely on the experts we have heard here today and others
throughout the country, to make good decisions that will target the real problems they
understand and that will achieve compliance with realistic goals. All issues should be
considered and all states must have the opportunity to prioritize what's important to them.
In fact, as a nation, we should address what is wrong and make changes to correct problems.
In closing, I would like to echo the comments of William Weeks of the Nature Conservancy,
where he said the essence of success is to accomplish conservation objectives, while co-
mingling the interests of all stakeholders. The industrial community agrees. We are happy
to be here. We look forward to working towards these goals; we look forward to meeting all
of you again, and to help you understand our concerns and to implement effective solutions.
Moderator: Our last speaker is Jessica Landman. She is a senior attorney at NRDC and she
is residing here in Washington, DC.
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Water Quality Criteria and Standards for the 21st Century
STAKEHOLDER OBSERVATIONS - Environmental Perspective
Jessica Landman
National Resources Defense Condi
Washington, DC
Good afternoon, I see I find myself as the last speaker, on the last panel of the last day,
during what for my daughter would be prime naptime. And so I guess I have to ask, is this
a reward or a punishment. Is this accident, coincidence. I just don't know what to make of
it. Thank you Betsy for the opportunity of being here. I will confess I have polled nobody
from the environmental community to give you reactions to the questions, so these can be
billed only as my opinion and nobody else, but I think that if you conducted an independent
and unscientific survey, you might find that many environmentalists if they were here, would
agree with me.
First, Should EPA put a higher priority on writing water quality criteria of the traditional sort,
or on developing methodologies for new types of criteria? My answer to that is that EPA
should target its criteria. That doesn't sound like a direct answer, does it Betsy. Now let me
be more general in my answer. EPA needs to have a system for deciding where its limited
resources on criteria development are going to go. We support the approach that's taken in
the area of effluent guidelines development, where EPA is compelled actually by the statute
but they certainly don't need a mandate from Congress to do this, to periodically review its
plans for how its going to develop criteria and where it's going to focus. Publish the proposed
criteria in the Federal Register. Ask interested stakeholders for their opinion and then write
that plan and abide by it. That's a pretty good idea. I don't really think any of us can give
them a useful answer to the question, unless we are getting very specific. What chemical
specific criteria are they proposing to write for us? I would like to see the proposed list, and
then I would like to give them my opinion on it. And I think EPA should be encouraged to
write a proposed plan for developing criteria in which they present what would be the best
and strongest case for specific criteria, chemical specific ones they are thinking about and for
the alternative ones they are thinking about in terms of sediment and wildlife and the like.
Then they should ask all of us for our opinions and then they should publish a plan reflecting
their considerations of those opinions. So let's have a system that all of us can systematically
comment on EPA's game plan and give them our input.
And then I'll turn to the either/or question. Should EPA develop criteria that consists of
default values that include the risk management component, or should they give the states
a range of values from which to select and focus on the risk assessment angle only? Here
I guess, I'd like to say my comments from here on in focus on a number of themes that I think
reflect concerns to the environmental community. I think those themes that are important and
what the conference has addressed already, are trust, accountability and fairness. People and
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citizens around the country, in environmental groups in particular, are having a problem with
the trust issue. We talked about that yesterday. And the fairness issue is one of growing
concern to us and to EPA, if you look at the President's Executive Order on Environmental
Justice, for instance, the question of fairness is a critical issue. My concern is that we need
to have some kind of national consensus achieved on some of the key risk management
decisions that are part of the water quality criteria. Let's take for example, the question of
cancer risk level. What level of risk is acceptable? Is it acceptable that one state would
conclude that their citizens would accept a one in ten thousand cancer risk for every pollutant
present in a complex waste stream? While the adjacent state picks a one in a hundred
thousand and the state upstream picks one in a million? I don't think that's fair, and I don't
think the public understands it and I think it contributes to the lack of trust that exists today
between industrial discharges for example and the community residents who live downstream
of their plants. And by the way, I don't mean to pick on industry here, but you are the ones
who have had to address this very issue in the permitting context. I think we need some
national dialogue on these questions, of what types of risk management decisions to make.
I do not think its appropriate for states individually to arrive at decisions on these risk
management questions that differ substantially and where it's clearly not fair to the citizens.
That's from the standpoint of those exposed and from the standpoint of those regulated. So
I favor default values based on risk management decisions and I also think its important that
those decisions reflect an open dialogue where we directly confront the question of how much
risk is appropriate and we reach some conclusions that apply to all of us around the country.
Next, Should EPA require states to adopt methods for essentially biocriteria such as nutrient
over enrichment? Gee, I can't believe we are asking this question. Of course, EPA should
require the states to adopt such methods. In fact, why in heavens name would states object
to being instructed to adopt such methods, when we know that these are the criteria that
provide us with useful measures about pollution problems that are attributable to polluted run-
off. When everybody knows that you need meaningful measures to evaluate that type of
pollution for purposes of accountability, for purposes of measuring water quality and having
some useful measure for which to see whether progress is being made. Everybody today and
yesterday has talked about the importance of performance and having goals to shoot for that
are meaningful and that are quantifiable. I don't think there is a cookie cutter set of nutrient
standards, for example, that are going to apply in every geographic region. Or that there are
going to be habitat criteria that are universally applicable. But that is not the question. I
notice Betsy that this question is very carefully worded. It talks about requirements that
methods be adopted. It does not talk about systematically adopting the same method coast-
to-coast. The point I guess that I'd like to focus on is that every state needs to have on the
books meaningful methodologies for evaluating whether they are addressing polluted run-off
sources. Therefore, EPA should require that they be adopted, but should be appropriately
flexible in making sure that states can adopt ones that make sense for their geographic
hydrologic situation.
The next question is What can EPA do to encourage the ecological risk assessment in high
priority watersheds? Well, I think that's an easy one. Give people money, and they will do
it. Just so you know, this was one of the issues that was considered in the context of the
Clean Water Act reauthorization. Congress was prepared to reward programs in which
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communities invested the necessary resources to develop a watershed based program and
showed they have a reasonable basis to conclude in that watershed there weren't going to
be problems. For example, if a community could show because of an overall risk assessment
that nutrients from sewage treatment plants would not cause problems, the community would
be allowed additional flexibility in areas such as the length of time for which sewage
treatment plant permits could be issued. In other words. Congress at least was willing to
consider the possibility that there could be flexibility in the standard permitting program in
those situations where a good case could be made, where that flexibility was appropriate.
I think a lot more discussion has to occur before everyone can be on board for exactly what
types of flexibility that might be. Longer permit terms was one thing Congress put on the
table and perhaps changing the terms of those permits is something I bet some of the people
in this room would like to put on the table. But the point is additional flexibility should go
along with additional accountability and ability to demonstrate there is a basis for that
flexibility. I think that's where the discussions ought to go.
Finally, we come back to that question on everybody's mind, should EPA continue the
independent applicability policy? I must say, this seems to me to be a tempest in a teapot,
but this is a battle in search of a battleground. In a sense, I think that there is an answer to
this dilemma in really good data collection, and really good understanding of ecosystems. And
maybe this is not a problem in North Carolina-is Steve Tedder still here? I'm not sure. Let's
say you have a water body where you can demonstrate that the EPA default criterion for a
metal is not appropriate because the local ecosystem is clearly supporting a balanced
indigenous population, natural background levels make it inappropriate, etc., etc. Isn't that
a case for a site specific water criterion? Why is that a case for kicking one of the legs out
from under the independent applicability stool? I just don't see this as a good place to shed
a lot of blood. It seems to me that a good state program isn't going to have to obsess on this
issue too much longer. Let me give you an example based on the trust concept of why we
have a problem with kicking one of the legs out from under the stool. A lot of environmental
groups do battle with the Corps of Engineers about dredging permits—the dredge and disposal
of contaminates. What we find and if there is anyone from the Corps of Engineers who would
like to challenge me, please don't raise your hand. A test is performed on those materials.
And the materials flunk the test. The Corps of Engineers searches and searches until it finds
another test to perform on those materials until ultimately there can be a test found that can
be performed on those materials, that the materials will pass. And then the materials can be
dredged and disposed. That is one perception of an attempt to kick a leg out from the stool,
and that is the trust problem that many of us probably confronts in dealing with environmental
problems at the local level. That's not a useful direction for this debate to go.
Let me end on a note of trying to look for ways that all of us can marshall our resources the
most effectively. We can work to consolidate and integrate reporting, monitoring and other
types of redundant requirements. Some of them may even be irrelevant but they consume
a lot of your efforts and ours too; 319 reports, 305B reports, 304L reports; the list goes on.
All of us in this room should turn to our colleagues in EPA and ask them, why can't all of
these requirements be consolidated, coordinated, and made more comprehensive and more
comprehensible to all of us. A few years ago EPA actually proposed a regulation that would
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have taken all of those reporting requirements and attempted to consolidate them and
coordinate them into one unified effort. That occurred, but they were somewhat constrained
by the statute in terms of the timelines for these things, but that occurred in an organized way
that made sense to everybody and could have saved us a lot of time. That was a really good
idea. I think it's one all of us could get behind, and I think it could be the first step in getting
behind something like instead of a triennial review, a review that occurs every five years,
instead of a biannual 305B report, one that occurs every five years. But one that contains
meaningful information. A 5-year review process that really brings all the stakeholders
together. If it happened less frequently, but more indepth it could probably have the support
of many of the people in this room. Those are the kinds of things I think all of us could
perhaps get together, agree on and maybe take our recommendations to the U.S. Congress,
and maybe they would follow our suggestion, if we all made it together.
Which brings me to the point that Bob Berger made earlier. Although many states are doing
a lot of good things and have made a lot of progress in addressing polluted run-off sources
despite the absence of a stronger Clean Water Act that mandates that we do something and
something enforceable with respect to polluted run-off, the fact is that a lot of states and EPA
are really waiting for a clear signal from Congress . We are losing out by not having had that
signal sent to us this year. For example, there was a presentation by Geoff Grubbs and others
today about the TMDL process. Learn everything you can about waste load allocation in the
absence of some mechanism to enforce a load application and make it meaningful with
respect to polluted run-off sources. A TMDL will remain nothing but a paper exercise in many
cases in many states. We really have to have a Clean Water Act that is more balanced in
terms of the types of powers and authorities that it gives the federal government and the
states to address polluted run-off sources as well as point sources.
Now why don't we have a stronger Clean Water Act this year? A number of people may have
touched on this yesterday, I know I did yesterday, talking about gridlock here in Washington.
Just so you know, not only would that legislation have given the states a lot more money, but
it would also have significantly rolled back some of the pending unfunded mandates that are
of the gravest concern to states who are trying to come up with the funds. Particularly in the
area of stormwater and combined sewer overflows. I'm sure you know that October 1 is the
deadline at which the moratorium on the obligation to have stormwater permits expires for
small communities. That moratorium, once it expires, means that small communities are in
fact liable for not having stormwater permits. I think this is an unfortunate situation. And one
thing that I had a very difficult time understanding this year is why it was that state water
quality agencies, the National Governor's Association and the National League of Cities did
not support the enactment of a stronger Clean Water Act which would give you the tools that
you need to address polluted runoff sources and get at some of the resource problems that
you states have. Maybe some of you have very strong reasons for having been concerned
about what was in those bills this year, but it's a lot of money that we are not going to be
seeing, and it's a lot of opportunities for more flexibility in addressing wet weather flows that
we're not going to be seeing as a result of the fact that that legislation didn't move. I guess
I'd just like to say, let's try harder next year to come to agreement on some of the key
improvements needed in the law and see if we can't move this process forward. Thank you
very much.
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Moderator: That completes our stakeholder observations, but we do have additional time
because we cut short the summaries of the session managers. Does anybody want to make
any comments regarding the questions that we had, or any comments in general about
implementation issues? Yes, in the back.
Comments from Audience.
My name is Larry Shepard. I'm with EPA Region 7 in Kansas City. And I'd just like
to make a very brief observation. If the definition of a stakeholder is someone who has a
different albeit, slightly different perspective on an issue or a problem, than say other
stakeholders, my observation is that if you look at the lineup of the stakeholders, the EPA
regions are noticeably absent. And I guess the observation I'd like to make is that EPA
regions are different than EPA headquarters because of the function they perform, which is
sort of to be the buffer between the regulated community, states and EPA headquarters. The
regions do have different perspectives, and I think throughout this whole meeting, I think the
perspective that the regions represent has been under represented in the meeting. So I just
wanted to share that thought.
Moderator: Well, do we have regional representatives here that would like to speak,
again it doesn't have to be on the questions we came up with for the stakeholder panel, but
just on any implementation issues?
Larry Shepard: I wouldn't presume to speak for all the regions, and I wouldn't even
presume to speak for Region 7, but I can speak for myself as the standards coordinator in
Region 7, and I guess I would like to mention a couple of things. One of them is in fact, what
I would consider to be my answers to some of the questions.
Moderator: Go for it.
Larry Shepard: Thank you. As far as the question whether EPA should be looking at
adopting new criteria, sediment criteria, wildlife criteria or more criteria, I think the answer
should be that basically what we need is different criteria. Part of the problem is we whereas
haven't exhausted the list of pollutants, we've covered a lot of categories. If you find metals
in sediment, the control strategies you would implement may largely be the same to control
all of those. If the NPDES permits says you have to take out lead, the chances are that
whatever you have to do to take out lead, would also take out copper. The same thing kind
of goes with the different kinds of organics, the bioaccummulatives, the fat soluble or water
soluble organics, the strategies for control tend to be the same. So I guess I would question
whether we need to have 142,000 criteria for organics, or whether we instead need to look
at the notion of assessment. In other words, what triggers our cleanup. If we look
somewhere and find a contaminant, or if we don't look for a particular contaminant, we never
get to the point of controls. If we have enough information that suggest a level of pollution
is bad, then we'll start that control process. So it seems if you've got enough pollutants on
hand that trigger your decision to take an action, then you're OK. The problem is where we
don't have the right end points in the case of sediments and wildlife. So I would say we
should start looking to new methods. Although, certainly in a perfect world you could do
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'•flboth, but I would point the other way.
As far as the notion as whether we should have ranges of values, standards
coordinators have been talking this week, and basically the way we feel is, you can do a risk
assessment and you come up with a range of values that can be explained and supported by
the notion of science. Although people have said that all science is good science, and if it's
not good science it's not science. But at any rate if you come up with a range, and you
support that with scientific position, however, you need one number to implement. You
cannot implement a range. If you passed the range on down to the states, they will pick a
number. Chances are the scientists won't pick a number. And chances are the risk managers
won't pick a number. The Governor will pick a number. The legislature will pick a number.
And the basis will not be technology, or science or risk management—it will be politics. So
what we have said is, do your risk assessment, get a range, pick a number as risk managers,
as EPA risk managers. Section 304A says EPA, that's what you are supposed to do. Get the
information, make a guidance recommendation, we'll send that down to the states. The
states always have the opportunity to go in and tweak one way or the other. Certainly they
can be more stringent, they can be even less stringent, as long as the rational is supportable.
What we have said is, get your risk assessment, get your range, EPA do the risk management
decision. Give us a number, pass it on down. Generally that's what everyone is looking for
in guidance. Because basically the regions or the states don't have the resources, the staffing
or the expertise to go to court and make defenses over every number that pops up. So we
need to do that at the headquarters level.
As far as independent application goes, not all the regions certainly present a unified
position. I won't speak to that, but I will say that we had a workshop in Kansas City about
three years ago, and one of the opponents of independent application said this is the way we
look at the independent application. I have three goals in life. One is to be the EPA
administrator, to win the lottery and win $ 10 million, and to marry some famous starlet. Now
just because I don't become the EPA administrator doesn't mean that that is a bad thing and
my life is a waste. Well basically that's the backwards way of looking at it. I have three
goals. One is to stay out of prison. One is not to get AIDS, and one is to keep all my natural
teeth. Now just because I don't keep all my natural teeth, means I should be happy about
that. So it's basically, instead of looking at three positive things, you should be looking at
three negative things. Just because you stay out of prison and you don't get AIDS, you
should be happy about having all you teeth fall out. So that's the way we look at
independent application.
The final thing I guess I would like to throw out for general thought is eco-risk. If you
look at EPA's efforts for biological criteria, part of the problem with getting states to get into
biological criteria is it is resource intensive, extremely resource intensive. If you ask people
from Region 5 how much money and how much time went into their program to get to the
point where they have numeric biologic criteria, it is astounding. It took years, and it took
thousands, and thousands of EPA dollars and state dollars and Ohio EPA has devoted handfuls
of their staff people to manage that program. And the states say yeah, that would be great,
can you give us the money like you did Ohio EPA? Can you give us more money to sustain
the staffing levels. Now for instance in Region 7, the states rely almost exclusively on EPA
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money to run the programs. The legislatures give virtually nothing to their state agencies to
run the program, and they depend on us to get it done. So, whereas we are now pouring
millions of dollars into the eco-regional approach and producing documents that can serve as
the ballasts on freighters in the Great Lakes, maybe if some of that money could be steered
toward the states. We keep talking about measuring and assessing, those biological criteria
are critical to that, and we're never going to go anywhere until we get the funds and
resources to get that done.
So although I agree with the eco-risk approach, I point out the resources that may or
may not be misdirected. I also point out that maybe instead of worrying about measuring eco-
risks, maybe we could take a look at the criteria we have in place or could have in place, if
we protect the components of the ecosystem. The sediment, the water column, wildlife, get
the biological assessment tools together, and if we implement those and NPDES permits and
non-point source controls, if they ever come. I would say this would go a lot farther to
protecting the ecosystem than if we spend hundreds of millions of dollars on pilot studies and
documents that are taller than most of us who work at EPA. At any rate, those are my
observations. Thanks.
Moderator: Thank you very much. There must be somebody else. I really want to
encourage you to speak out. I think there have been some side bar conversations over the
past three days, and this is a chance to do it in a plenary session. We have all the managers
here from the program, and they really want to hear from you. Go ahead.
Thanks, I'm with EPA Region one, which is New England. I guess thinking about EPA
regions, I said well yeah, we do have a different point of view. So I'm involved in a holistic
watershed management project called the Merimac River Initiative. And just through that
experience we've gone through a lot of what we've talked about here, the stakeholder
involvement, the problem definition, all these things, and one of the real life observations
we've made is so much of the decisions aren't at the local level. Maybe it's New England
more than other places, but one of the biggest things we hear from the local people is the
need for more information, for them to make informed decisions in a watershed context. And
it's surprising to me that I haven't heard many people talk about information and the need to
get information to the public who are the decision-makers. So I guess, you know, people talk
about education and that sort of thing. But I think information management has become a
pretty critical part of my watershed initiative. And I'm surprised I haven't heard more about
it. And I guess one other observation is I still feel like there's a pretty big schism between the
standards people and the way they talk and the watershed people. I consider myself a
watershed person and not a standards person and I still feel like we need a lot of talking to
come to a place where we can go to the stakeholder who really will be the steward. I really
appreciate hearing from industry and environmental groups. I think that's terrific.
Moderator: Thank you. Can you clarify a little bit? What do you think the disconnect
is between the standards and the watershed approach. Because presumably the standards
are a tool of the watershed approach.
Region One Commenter: I know, but I think there is some language problems. The
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fellow from the Nature Conservancy also, it's just a language problem. When I go to talk to
the public about designated uses and things like that. There is still some misunderstanding
about what that really means for their lives. This reminds me of something else we are
thinking about, going to the public to talk about designated uses again, and then what does
that mean for standards and criteria, if those change.
Moderator: Ok. There were some excellent presentations yesterday on different types
of designated uses. Any other people want to speak. Yes, over here.
Commenter: Hi. Tom Brosden, the New York City Environmental Protection. I just
had a comment on independent applicability. I think some of the reasons people get kind of
nervous about this is particularly when they are dealing with some of the standards that are
outdated. A case in point was the salt water copper standards which many of you know
about. We had a problem in New York, exceedances of the copper standards even though
the biology in the receiving waters did not show a problem. And, Jessica, we did exactly
what you implied. We did a site specific criteria, and we did it in conjunction with EPA and
it worked out well. In fact, it cost almost $1 million to do a site specific criteria, and that's
not an unusual price for some of the other ones that have been attempted. It took almost
three years to complete. To update a criteria when we couldn't find a problem to begin with
in the harbor. It's just a word to the wise. A site-specific criteria is one of the last things
anybody wants to get into, because they are difficult to do and so costly and they divert
resources from what we consider to be real problems like PCBs in fish, mercury in sediments,
things like that. A final thing on independent applicability. Everyone is taking it as an all or
none. Perhaps what we could do is just have a weight of evidence. You can use all three
legs of the independent applicability, but have perhaps the biological evidence be weighted
higher than the chemical evidence, which would be weighted higher than the wet testing
which seems to be the least definite indicator of all.
Moderator: Thanks, that's an interesting suggestion. Anybody else?
Commenter: We are looking at a couple of things that we have been dancing around.
Mike Harris from Amoco. One of the things that we are dancing around is for permit holders
or responsible people whether they are non-point source or point-source if you are using a
biological criteria or watershed ecological risk assessment, and the answer comes back. Gee,
there still is an impairment. But the analysis says it has nothing to do with what I'm involved
with. Whether its toxic or a non-toxic sediment. How are you going to handle that issue?
In other words, you've got a three legged stool you fail a lab criteria, because the receiving
water is impaired but when anybody looks at it it's because of something that has nothing to
do with your discharge or run-off. That's one issue. Then it's going to be the same situation
when you start looking at habitat impairment where the area is impaired but it's not a
pollution problem. How are you going to deal with the various people you have to work with?
There are decisions you have to address there, so don't ignore them while you attempt to
embrace a new approach. The other thing when you talk about new standards, new criteria,
keep in mind, this is one of the things that our Yorktown pollution prevention project came
up with and emphasized. It's not a freebie to take it out of the water. If you take it out of
the water, it goes some place else. In other words, there are some sort of perhaps indirect
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Southerland/Stakeholder Observations
Water Quality Criteria and Standards for the 21st Century
environmental costs associated with implementing a water specific criteria. And the multi-
media issue is one thing I know EPA is aware of in the program offices, and now you are
saying the place rangers, but keep in mind there are costs associated with implementing a
specific criteria in terms of media transfer. Not everything will be destroyed; not everything
at least in my industry where you take a raw material, petroleum and crude and you refine it.
It's hard to change what's in a crude oil.
Moderator: Thank you very much. Anybody else? Yes.
Commenter: Mary Jo Garreis, Maryland Department of Environment. Concerning the
need for specific state direction or requirements on the states to address issues like sediment,
nutrients, whatever. I think that would be a mistake. And I believe that it would be because
if EPA is very serious about this watershed approach; and if it actually works as we envision
that it should, for every watershed that it is attempted on, those things are going to fall out.
The watershed is going to point out whether you need nutrient requirements, whether you
need whatevers, and I think the Chesapeake Bay experience has shown that when that
happens, you can do a lot more with peer pressure, voluntary control in the absence of
mandated regulatory control. I think we should give that opportunity to work rather than go
into the command and control kind of requirements again to set up barriers that slow us down
instead of actually accomplishing what we think they should do.
Moderator: Thank you. Anybody else?
Commenter: I'm Bob Oberthaler, State of New Jersey. One question on prioritization
of types of criteria. Basically I think we need a balance of the kinds of specifics as well as
the other tools to be developed, and I would like to echo what some of the speakers said
about a schedule. A lot of us are in the midst of rule-making at the states and we don't know
what EPA's schedule really is in the times we have gone out with rule-makings. Then EPA
will come out with something and as I believe the man from Illinois said, sometimes it takes
years to do these proposals. And we are in the middle of a proposal and the very thing EPA
comes out with will be used against us on our proposal as we don't have up-to-date science
or we aren't following the most current guidance from EPA. It puts us in a very embarrassing
position because we didn't know the Agency was coming out with these things. The other
thing is it doesn't matter to me whether it goes in the Federal Register as much but at least
it's out there and people are aware of it, and that EPA delivers on time. That's another thing
we hear, guidance is coming, guidance is coming and then sometimes it doesn't come. We
don't know why it doesn't come, it just doesn't come. In terms of the overall conference
proceedings I think one person said that it would be fruitful if a strategy would come out of
this.
I was talking with Mary Jo at lunch, and she echoed that as well, that there should be a
strategy. I had a comment yesterday, it would be nice to have a draft strategy developed and
EPA went on the road into the regions with the draft strategy and got further stakeholder
participation from the states, as well as the regulated community and environmental
community. And then finalize that strategy. One of the elements that should be in it would
be what she just kind of implied, is that it would be good to have voluntary things in terms
of these new initiatives.
6-23
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Southerland/Stakeholder Observations
Moderator Comment: And the strategy would riot just be on criteria development
schedules, but would be on the implementation schedules also.
Bob Oberthaler: Yes. Thank you.
Moderator: Anybody else? Regions, States, anybody? Ok. With that we're going to
close. I'd like to give another big hand for the stakeholder panel, and then we'll turn it over
to Tudor Davies for his closing remarks.
6-24
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I
Closing Remarks
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Davies
Water Quality Criteria and Standards for the 21st Century
CLOSING REMARKS
Tudor T. Davies
Director, Office of Science and Technology
U.S. EPA
Thank you all for being here. It's been excellent hearing your input and ideas. It's going to
take us all time to review what we've heard, the side bar conversation we've had, as well as
the formal presentations. I'd like to thank the staff who put all the time into getting all the
speakers here, and the speakers for preparing. And I'd like to thank the people who cornered
me in the corridor to give me their individual viewpoints so I would know all the things we do
wrong and all the things we can do better. We'll think about those and try to help.
I think there were very thoughtful summaries here today. I think there were very thoughtful
remarks at the end which I think reflect some major concerns in our community about how
we actually move forward from the traditional criteria and standards program that we're all
used to, to what may be a future program. We feel somewhat committed to at least in
headquarters, although I hear the regions may not be the same degree of commitment, to
moving forward from the traditional programs to looking at ecosystems in watersheds. We
have some change to make in terms of philosophy. We have some risks to take, and we have
to make the whole community comfortable in this movement. The Administrator expressed
three major priorities that she was concerned about, the first being that nature is a system,
that we don't move pollutants from one place to another. Secondly, that we think about
pollution prevention, and thirdly, that we involve stakeholders. And we heard that from Bob
Perchiasepe too. And I think Bob's concern was that we move forward on the basis of the
base program that we have built over time. We have a lot of success, we should move
forward from that base.
I think the following comments that I heard during the week, characterize the essence of this
meeting.
Ecosystems are more complicated than we think was an interesting comment that I heard this
morning. Another was communicated by one of the people who is concerned about whether
we could move forward from the existing criteria and standards program. This person said
to me, "Can the regulatory framework of the criteria and standards get us to ecosystem
protection?" I think that is something we have to think about.
Then someone talked about science as a successive approximation to the truth. And I think
we need to bear that very carefully in mind. And I loved the comment that Jessica had
yesterday in terms of flexibility and particularly in terms of the independent applicability
program. She indicated that you get flexibility perhaps by earning it. I didn't quite like
"earning it", but the idea is that we can have flexibility in our system. We can have a
6-25
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Davies
relaxation of the independent applicability process, but what we've got to do is have
information to show that we are protecting the environment either through criteria, either
through biological indication or through effluent toxicity. We have had cases made to us
where we've been shown that the information content lies in the biology and not in the
criteria, and that we should understand, but we have to have information to make those
judgments. We can't do it strictly on trust. And the statement that I thought was the most
marvelous one of the whole meeting talked about competition between alternative uses and
I think we'll all go away thinking about this. I thought that was a wonderful statement.
I think some of the things we have to do as we go away from here is we must continue
education and outreach in the criteria and standards program. I think the academies we have
run with the regions have been very successful. We have new programs that are coming on
line with the tribes; we have new people coming into the states; and I think it's important that
we continue this academy program that we ran this last year. We have had hundreds of
people that have been involved in that, and I've had very strong comment on how useful and
important they are. We've also run a series of workshops that have been mentioned on
particular issues. I think that I would like to see those expanded over the next years so that
we put more time on working with the states, regions and other stakeholders, particularly on
regional issues. This is the way that we can share information and perhaps get out of this
fear that I think is in the system about relaxing from our traditional programs as we move into
watershed programs. I also need to say to respond to Bob Berger and to other commenters
I heard, we want to have you involved as we develop procedures, guidance and new science.
I think the model of the Annapolis meeting where we talked about metals is a good one. We
got scientists, regulators, the affected people together to talk about the issues. This was a
good meeting and we would like to use that model more into the future. I also sensed here,
and I guess sensed elsewhere, that we, perhaps I should say the states, the EPA, the regions,
the dischargers, we have a certain culture, we have a certain way of thinking and we are not
well integrated with the resource industry. We've got a different philosophy, we've gone a
different way with our science, and we're going to have to communicate better with them as
we look at ecosystems and ecological protection. And I think we all have to step out to try
to make that bridge. I've been working extensively on endangered species act coordination,
and there are different philosophies, there is not a trust between us in those communities, and
we have to build that.
We will work on a number of things over the next year that we'll involve you with. Use
astainability analysis, and risk assessment, improving designated use guidance. We will try
to make TMDLs more user friendly. And we hope that the contaminated sediment
assessment will help you with your watershed listings. We're going to work on biological
assessments of criteria; we will be seeking strong input on the over enrichment, nutrient
criteria area, and also with human health methodology, particularly on mercury, dioxins, and
lead. We will be looking to have involvement on an implementation manual for sediment
criteria, in terms of the conceptual background to that. And we will be giving you lots of
information on metals over the next period. As you know, we have done a reexamination of
what we should use for metals. We are thinking very seriously about the dissolved metal
issue. We are working with USGS to get out new clean techniques for measuring metals that
will be developed over the next couple of months and also sampling techniques so that what
6-,26
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Davies Water Quality Criteria and Standards for the 21st Century
we are dealing with is the real concentrations rather than the contaminated concentrations
we have been dealing with in the past. So look for that information. We'll be looking for
comment on it. I hope that that will solve some of the metals problems that we talked about
when people go out and do site-specific criteria, and have problems with measuring levels of
metals in the environment that are not the actual levels that are affecting organisms.
Guidance on eco-risk assessment is something we'd like your involvement with, and I will
continue to have dialogue on independent applicability.
One of the things I'd like to suggest over time and it's something we have suggested to our
Administrator, is that we would like to specifically work with some pilot states on ecosystem
management. You could have a lot of innovation, frankly the states try things usually before
the federal government does. So if there are some states that would be interested in working
with EPA headquarters, and regions perhaps on independent applicability, or different ideas
on watershed approaches, we would like you to approach us so we could perhaps help with
people and maybe some money, so we could move forward in this area.
I think that the concept of having a watershed strategy is one that the Office of Water
endorses. We have tried to put together some structures to develop that strategy. The
agency itself has a broader strategy to think about watersheds. And the example that we
took for the contaminated sediment strategy, where we developed the strategy, published it
and then we went out and had workshops may be again, what I think someone was
suggesting, to get a strategy, take it out on the road and see what people think about it. I'll
take that back.
The concept of a proposed plan for criteria development was one that was in the green book.
The green book was the government proposal for the Clean Water Act. We there talked about
having a plan, like the 304{m) plan that Jessica talked about for criteria development and
guidance. I think that's still a good idea, something we should follow up on. And then we
could get your comment on where we are going in a formal fashion.
I think the agency is sympathetic to the idea of longer periods for review of triennial review
of standards; longer periods for permits is something again we talked about in the Clean
Water Act. I think those are the things we should continue to have a dialogue on. I don't
think anybody within EPA disagrees that we have got to deal with non-point source issues.
We are dealing with it in some places. We're dealing with it where we have money, but it is
I think the future for us. We were all exceedingly disappointed that we didn't have a Clean
Water Act that allowed us to begin addressing that. We were looking for a signal. I think
Jessica was right in that. We've got to move in some other way, and perhaps the farm bill
of next year will be another mechanism for us to work with the Congress on this issue.
That's all I have to say. Again thank you so much for coming. Have a safe journey home.
Thank you for you input. We'll reflect on your comments, and hopefully get the proceedings
out quickly. Please be involved with us as we in a broader EPA sense work on the strategy
that is needed for watershed and the issues for criteria and standards.
Thank you again.
6-27
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Speakers List
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Final Speakers' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Appendix A
Mr. Richard Anderbery
Water Quality Coordinator
Tri-Basin Natural
Resources District
1308 Second Street
Holdrege,NE 68949
(308) 995-6688 FAX (308) 995-8760
Mr. Kevin J. Beaton
Deputy Attorney General
Environmental Affairs
Idaho Office of
Attorney General
1410 N. Hilton Street
2nd Floor
Boise, ID 83706
(208) 334-0494 FAX (208) 334-0576
Robert T. Angelo, Ph.D.
Chief
Science and Standards Section
Kansas Dept. of Health
& Environment
Forbes Field, Bldg. 740
Topeka,KS 66620-0001
(913) 296-8027 FAX (913) 296-6247
Mr. John Bender
Water Quality Coordinator
Nebraska Dept. of
Environmental Quality
1200 N Street
P.O. Box 98922
Lincoln, NE 68509-8922
(402)471-4201 FAX (402) 471-2909
Mr. Thomas M. Armitage
Acting Chief, Risk Assessment Mgmt. Branch
Standards and Applied Science Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
RoomE939D
Washington, DC 20460
(202) 260-5388 FAX (202) 260-9830
Mr. Bob Berger
East Bay Municipal
Utility District
P.O. Box 24055
Oakland, CA 94623
(510) 287-1617 FAX (510) 287-1351
Mr. Richard Batiuk
Toxics Coordinator
U.S. EPA - Region 3
Chesapeake Bay Program Office
410 Severn Avenue
Suite 109-110
Annapolis, MD 21403
(410)267-5731 FAX (410) 267-5777
Mr. Jeffrey Bigler (4305)
Fisheries Biologist
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202)260-1305 FAX (202) 260-9830
9/19/94
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Final Speakers' List
Water Quality Criteria arid Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Peter Bowler
Dept. of Ecology and Evolutionary Biology
University of California
Irvine
Irvine, CA 92717
(714) 856-5183 FAX (714) 725-2181
Mr. Dale Bryson
Director, Water Division
U.S. EPA - Region 5
77 W. Jackson Blvd.
Chicago, IL 60604-307
(312) 353-2147 FAX (312) 886-0957
Mr. Donald J. Brady (4503F)
Watershed Branch
U.S. EPA- Office of Wetlands,
Oceans, & Watersheds
401 M Street, SW
Washington, DC 20460
(202) 260-5368 FAX (202) 260-7024
Ms. Mary Buzby
Merck & Co., Inc.
P.O. Box 100
Merck Drive
Whitehouse Station, NJ 08889-0100
(908) 423-7837 FAX (908) 735-1109
Mr. David P. Braun
Hydrologist/Water Quality Specialist
The Nature Conservancy
1815 N.Lynn Street
Arlington, VA 22209
(703) 841-8784 FAX (703) 247-3674
Mr. John Christian (H652)
Assistant Regional Director
Fisheries and Federal Aid
U.S. Fish and Wildlife Service
1 Federal Drive
BHW Federal Bldg.
Fort Snelling, MN 55111
(612) 725-3505 FAX (612) 725-3343
Ms. Carol Browner
Administrator
U.S. EPA
401 M Street, SW
RoomW1200
Washington, DC 20460
(202) 260-4700 FAX (202) 260-0279
Ms. Patricia Cirone
Environmental Services Division
U.S. EPA - Region 10
1200 Sixth Street
Seattle, WA 98101
(206)553-1597 FAX (206) 553-0119
9/19/94
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Final Speakers' List
j
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Susan M. Cormier, Ph.D.
Ecological Monitoring Research Division
U.S. EPA - Office of
Research and Development
26 W. Martin Luther King Drive
Cincinnati, OH 45268
(513)569-7995 FAX (513) 569-7609
Ms. Julie DalSoglio
Remedial Project Manager
U.S. EPA - Region 8
Montana Operations Office
301 S. Park - Drawer 10096
Federal Building
Helena, MT 59626-5432
(406) 449-5720 FAX (406) 449-5434
Mr. Joseph E. Costa
Director
Buzzards Bay Project
2 Spring Street
Marion, MA 02738
(508) 748-3600 FAX (508) 748-2845
Mr. Tudor T. Davies (WH-551)
Director
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Room E737A
Washington, DC 20460
(202) 260-5400 FAX (202) 260-5394
Mr. Joel Cross
Division of Water Pollution Control
Illinois EPA
2200 Churchill Road
Springfield, EL 62794-9276
(217) 782-3362 FAX (217) 785-1225
Mr. Max H. Dodson(8WM)
Director
Water Management Division
U.S. EPA - Region 8
999 18th Street
Suite 500 "
Denver, CO 80202-2405
(303) 293-1542 FAX (303) 294-1386
Mr. Paul J. Currier
Deputy Director
Platte River
Whooping Crane Trust
2550 N. Diers Avenue
Suite H
Grand Island, NE 68803
(308) 384-4633 FAX (308) 384-4634
Ms. Cynthia Dougherty
Director
U.S. EPA - Permits Division
401 M Street, SW
Washington, DC 20460
FAX (202) 260-1460
9/19/94
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Final Speakers' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Tim A. Eder
National Wildlife Federation
506 E. Liberty Street
2nd Floor
Ann Arbor, MI 48104
(313) 769-3351 FAX (313) 769-1449
Mr. Tom Fontaine
South Florida Water
Management District
3301 Gun Club Road
West Palm Beach, FL 33416
(407) 686-8800 FAX (407) 687-6442
Mr. Jack Edmundson
Branch Chief
APHIS/BBEP
U.S. Dept. of Agriculture
Envir. Analysis & Documentation
6505 Belcrest Road
#543
Hyattsville, MD 20782
(301) 436-8274 FAX (301) 436-3368
Ms. Catherine A. Fox (4305)
Environmental Scientist
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-1327 FAX (202) 260-9830
Ms. Elizabeth Fellows (WH-553)
Chief, Monitoring Branch
Assessment & Watershed Protection Division
U.S. EPA - Office of Wetlands,
Oceans, & Watersheds
401 M Street, SW
RoomE835
Washington, DC 20460
(202) 260-7062 FAX (202) 260-7024
Ms. Christine R. Furr
Land Use Planner
Christine Furr Consulting
6579 Strathcona Avenue
Dublin, OH 43017
(614) 792-7545 FAX (614) 792-7545
Mr. Morris C. Flexner
Environmental Scientist
Water Management Division
U.S. EPA - Region 4
345 Courtland Street, ME
Atlanta, GA 30365
(404) 347-3555 x6549 FAX (404) 347-5204
Ms. Maggie Geist
Research Translator
Waquoit Bay National
Estuarine Research Reserve
P.O. Box 3092
Waquoit, MA 02536
(508) 457-0495 FAX (617) 727-5537
9/19/94
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Final Speakers' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Steven I. Gordon, Ph.D.
Dept. of City and Regional Planning
Ohio State University
289 Brown Hall
190 W. 17th Avenue
Columbus, OH 43210
(614)292-3372 FAX (614) 292-7106
Ms. Margarete Heber (4304)
Health and Ecological Criteria Division
U.S. EPA -Office of
Science and Technology
401 M Street, SW
RoomElOOlA
Washington, DC 20460
(202)260-7144 FAX (202) 260-5394
Mr. Geoffrey H. Grubbs (4503)
Director
Office of Assessment & Watershed Protection
U.S. EPA - Office of Wetlands,
Oceans, & Watersheds
401 M Street, SW
Washington, DC 20460
(202) 260-7040 FAX (202) 260-7024
Mr. William F. Hoffmann (4305)
Environmental Scientist
Standards and Applied Science Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-0642 FAX (202) 260-9830
Mr. James A. Hanlon (WH-551)
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Room E737B
Washington, DC 20460
(202) 260-5400 FAX (202) 260-5394
Mr. James G. Home (WH-546)
Special Assistant to the Director
U.S. EPA - Office of
Wastewater Management
401 M Street, SW
RoomNE201C
Washington, DC 20460
(202)260-5802 FAX (202) 260-1040
Mr. Geoffrey W. Harvey
Senior Surface Water Analyst
Divison of Environmental Quality
Idaho Dept. of Health and Welfare
Northern Idaho Regional Office
2110 Iron wood Parkway
Coeur d'Alene, ID 83814
(208)769-1448 FAX (208) 769-1404
Ms. Susan Jackson (4304)
Environmental Scientist
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Room E1016
Washington, DC 20460
(202) 260-1800 FAX (202) 260-5394
9/19/94
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Final Speakers' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Jerry Johns
Asst. Division Chief
Division of Water Rights
California State Water
Resources Control Board
901 P Street
P.O. Box 2000
Sacramento, CA 95816
(916) 657-1981 FAX (916) 657-1485
Ms. Jessica C. Landman
Senior Attorney
Natural Resources
Defense Council
1350 New York Avenue, NW
Suite 300
Washington, DC 20005
(202) 783-7800 FAX (202) 783-5917
Mr. Charles A. Kanetsky
Region Water Quality Monitoring Coordinator
U.S. EPA - Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-8176 FAX (215) 597-7906
Ms. Amy Leaberry (4304)
Biologist
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Room E1043 A
Washington, DC 20460
(202)260-6324 FAX (202 ) 260-1036
Mr. Russ Kinerson(4305)
Standards and Applied Science Division
U.S. EPA-Office of
Science and Technology
401 M Street, SW
RoomE935
Washington, DC 20460
(202) 260-1330 FAX (202) 260-5394
Ren Lohoefener, Ph.D. (452-ARLSQ)
Chief, Recovery and Consultation Branch
Div. Endangered Species
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive
Arlington, VA 22203 -
(703)358-2171 FAX (703) 358-1735
Mr. Bill Kittrell
Clinch Valley Bioreserve Manager
The Nature Conservancy
102 S. Court Street
Abingdon,VA 24210
(703)676-2209 FAX (703) 676-3819
Mr. Jeremiah L. (Jay) Maher
Relicensing Coordinator
Central Nebraska Public
Power & Irrigation District
415 Lincoln Street
P.O. Box 740
Holdrege,NE 68949
(308) 995-8601 FAX (308) 995-5705
9/19/94
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Final Speakers' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Suzanne K. M. Marcy, Ph.D. (4304)
Biologist
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
RoomElOOlC
Washington, DC 20460
(202) 260-0689 FAX (202) 260-1036
Mr. John E. Miller (5204G)
Environmental Scientist
U.S. EPA - Office of Solid Waste
and Emergency Response
401 M Street, SW
Washington, DC 20460
(703) 603-9076 FAX (703) 603-9103
Mr. Robert F. (Mike) McGhee
Acting Director, Water Management Division
U.S. EPA - Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4450 FAX (404) 347-5204
Mr. Bob Muffley
Gooding County, Idaho
122 5th Avenue West
Gooding, ID 83330
(208)934-4781 FAX (208) 934-5648
Ms. Janet McKegg
Director
Maryland Dept. of Natural Resources
Natural Heritage Program
580 Taylor Avenue
Annapolis, MD 21401
(410) 974-2870 FAX (410) 974-5592
Ms. Jennie Myers
Latin America-Caribbean Division
Consultant to
The Nature Conservancy
13 Standish Street
Cambridge, MA 02138
(617) 492-7360
Mr. Estyn R. Mead
Fish and Wildlife Biologist
Division of Habitat Conservation
U.S. Fish"and Wildlife Service
4401 N. Fairfax Drive
400 Arlington Square
Arlington, VA 22203
(703) 358-2183 FAX (703) 358-1869
Mr. Darren S. Olsen
Nez Perce Tribe
Water Resources
Box 365
Lapwai, ID 83540
(208)843-7368 FAX (208) 843-7371
9/19/94
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Final Speakers' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Robert Paulson
Environmental Toxicologist
Bureau of Water Resources Management
Wisconsin Dept. of
Natural Resources
Box 7921
WRI2
Madison, WI 53707-7921
(608) 266-7790 FAX (608) 267-2800
Mr. Brian D. Richter
Biohydrology Team Leader
The Nature Conservancy
2060 Broadway
Suite 230
Boulder, CO 80302
(303) 541-0339 FAX (303) 449-4328
Mr. Robert Perciasepe (4101)
Assistant Administrator
U.S. EPA - Office of Water
401 M Street, SW
Room E1032
Washington, DC 20460
(202) 260-5700 FAX (202) 260-5711
Mr. Michael A. Ruszczyk
Environmental Chemist
Eastman Kodak Co. - Corporate
Health, Safety & Environment
1100 Ridgeway Avenue
Rochester, NY 14652-6263
(716)722-3805 FAX (716) 722-3695
Alan Randall, Ph.D.
Professor
Dept. of Agricultural Economics
Ohio State University
2120 Fyffe Road
Columbus, OH 43210-1099
(614) 292-6423 FAX (614) 292-0078
Mr. David Sabock (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
RoomE919A
Washington, DC 20460
(202) 260-1315 FAX (202) 260-5394
James J. Reisa, Ph.D.
Director
Environmental Studies & Toxicology
National Research Council
2101 Constitution Avenue, NW
HA354
Washington, DC 20418
(202) 334-3060 FAX (202) 334-2752
Ms. Donna F. Sefton (4503F)
Watershed Protection Approach/
Platte Watershed Coordinator
U.S. EPA - Office of Wetlands,
Oceans, & Watersheds
401 M Street, SW
Washington, DC 20460
(202)260-7105 FAX (202) 260-7024
9/19/94
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Final Speakers' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Robert J. Smith
Competitive Enterprise Institute
1001 Connecticut Avenue, NW
Washington, DC 20036
(202) 331-1010 FAX (202) 331-0640
Mr. Ed Stigall
Chief, Technical Programs
U.S. EPA - Region 3
Chesapeake Bay Program Office
401 Severn Avenue
Suite 109-110
Annapolis, MD 21403
(410) 267-5740 FAX (410) 267-5777
Mr. Marc A. Smith
Environmental Supervisor
Ecological Assessment Section
Ohio EPA
Division of Surface Water
1685 Westbelt Drive
Columbus, OH 43228
(614) 728-3384 FAX (614) 728-3380
Edward B. Swain, Ph.D.
Research Scientist
Minnesota Pollution
Control Board Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-7800 FAX (612) 297-8701
Ms. Betsy Southerland (WH-585)
Director,
Standards and Applied Science Division
U.S. EPA-Office of
Science and Technology
401 M Street, SW
Room E835
Washington, DC 20460
(202) 260-3966 FAX (202) 260-5394
Mr. Steve W. Tedder
Chief, Water Quality Section
Division of Environmental Management
North Carolina Dept. of Environ.
Health & Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
(919) 733-5083 FAX (919) 633-9919
Ms. Margaret Stasikowski (WH-586)
Director
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
RoomE735C
Washington, DC 20460
(202) 260-5389 FAX (202) 260-1036
Philip G. Watanabe, Ph.D.
Director
Health & Environmental Sciences
Dow Chemical Company
1803 Building
Midland, MI 48674
(517) 636-1313 FAX (517) 636-1875
9/19/94
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Final Speakers' List
Water Quality Criteria arid Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. W.William Weeks
Chief Operating Officer
The Nature Conservancy
1815 N.Lynn Street
Arlington, VA 22209
(703) 841-4853 FAX (703) 841-8796
Mr. Chris O. Yoder
Manager, Ecological Assessment Section
Division of Surface Water
Ohio EPA
1685 Westbelt Drive
Columbus, OH 43228
(614) 728-3382 FAX (614) 728-3380
Mr. William S. Whitney
Director
Prairie Plains
Resource Institute
1307 "L" Street
Aurora, NE 68818-2126
(402) 694-5535 FAX (402) 694-4426
Mr. Chris Zarba (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
RoomElOOlB
Washington, DC 20460
(202) 260-1326 FAX (202) 260-5394
Mr. Larry R. Wimer
Manager, Hydro Relicensing and Compliance
Idaho Power Company
P.O. Box 70
Boise, ID 83707
(208) 383-2727 FAX (208) 362-4385
Mr. Patrick Wright (W-2-4)
Chief, Bay/Delta Section
U.S. EPA - Region 9
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1993 FAX (415) 744-1078
10
Q/1Q/Q4
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I
Final
Attendees List
-------
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Joan Abbott
NCASI
Tufts University - Anderson Hall
Medford,MA 02155
(617) 627-3254 FAX (617) 627-3831
Ms. Lisa Almodovar (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Ralph W. Abele
U.S. Fish and
Wildlife Service
300 Westgate Center Drive
Hadley, MA 01035
(413) 253-8606 FAX (413) 253-8482
Mr. John A. Alter
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202) 260-4315
Mr. Charles Adams
U.S. General Accounting Office
800 - K Street
Suite 200
Washington, DC 20001
(202) 512-8010 FAX (202) 336-6501
Ms. Melissa Amos
Wyer Management Associates
P.O. Box 1310
Orange, VA 22960
(703) 672-2221 FAX (703) 672-9201
Mr. Eugene T. Akazawa
Clean Water Branch
Hawaii Dept. of Health
919 Ala Moana Blvd.
Room 301
Honolulu, HI 96814
(808) 586-4309 FAX (808) 586-4352
Mr. Terry P. Anderson
Kentucky Division of Water
14 Reilly Road
Frankfort, KY 40601
(502) 564-3410 x401 FAX (502) 564-4245
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Duane Anderson
Minnesota Pollution
Control Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-9315 FAX (612) 297-8683
Sue Anne Assimon, Ph.D.
Food and Drug Administration
200 "C" Street, SW
" Washington, DC 20204
FAX (202) 260-0498
Ms. Jude Andreasen (4603)
U.S. EPA - Office of
Groundwater & Drinking Water
401 M Street, SW
Washington, DC 20460
(202) 260-5555 FAX (202) 260-3762
Mr. Larry Ausley
North Carolina Div. of
Environ. Management
4401 Reedy Creek Road
Raleigh, NC 27607
(919) 733-2136 FAX (919) 733-9959
Mr. Robert W. April (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Larry Bahr
Fairfield-Suisun
Sewer District
1010 Chadbourne Road
Fairfield, CA 94585
(707)429-8930 FAX (707) 429-1280
Mr. Peter Archuleta
Eastern Municipal
Water District
P.O. Box 8300
San Jacinto, CA 92581-8300
(909) 925-7676 x311 FAX (909) 929-0257
Mr. David E. Bailey
Manager
Water & Land Programs
Potomac Electric Power
1900 Pennsylvania Avenue, NW
Washington, DC 20068-0001
(202) 331-6533
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Rodger Baird
Los Angeles County
Sanitation District
1965 S. Workman Mill Road
Whittier, CA 90601
(310) 699-0405 FAX (310) 695-7267
Ms. Dianne Baucom
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-8822 FAX (202) 260-5394
Mr. Fred Banach
Connecticut Department
of Environmental Protection
79 Elm Street
Hartford, CT 06438
(203)424-3712
Ms. AnnBeier(4503F)
U.S. EPA - Office of Wetlands,
Oceans, & Watersheds
401 M Street, SW
Washington, DC 20460
(202)260-7108 FAX (202) 260-7024
Mr. Charlie Bare
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
Mr. Mary L Belefski
U.S. EPA
401 M Street, SW (4503F)
Washington, DC 20460
(202) 260-7061 FAX (202) 260-1977
Mr. Thomas Barron
Pennsylvania Dept. of
Environ. Resources
400 Market Street
10th Floor
Harrisburg, PA 17105-8465
(717)787-9637 FAX (717) 772-5156
Mr. Kenneth T. Belt, P.E.
Pollution Control Analyst Supervisor
Environmental Services Division
City of Baltimore
3001 Druid Park Drive
Baltimore, MD 21215
(410) 396-0732
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Steve Bennett
Prince William County
Service Authority
P.O. Box 2266
Woodbridge, VA 22193-0266
(703) 670-8101 FAX (703) 670-8101
Ms. Mary Blakeslee (4304)
Policy and Communications Staff
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Ms. Marian Berkowitz
Environmental Health Services
New Jersey Dept. of Health
CN-360
Trenton, NJ 08625-0360
(609) 984-2193 FAX (609) 984-2192
Ms. Linda Blankenship
Water Environment Federation
601 Wythe Street
Alexandria, VA 22314-1994
(703) 684-2473 FAX (703) 684-2492
Mr. Paul Bernard
Rust Environmental &
Infrastructure
11240 Waples Mill Road
Fairfax, VA 22030
(703) 385-3566 FAX (703) 385-8319
Michael Bolger, Ph.D.
Food and Drug Administration
200 "C" Street, SW
Washington, DC 20204
FAX (202) 260-0498
Mr. Nizam bin Basiron
ASEAN-CPMS H
Malaysia
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604) 986-4331 FAX (604) 662-8548
Mr. Robert Boone
Anacostia Watershed Society
5110RoanokePlace
#101
College Park, MD 20740
(301)513-0316 FAX (301) 513-9321
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Denis R. Borum (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Dan Bruinsma
City of San Jose
Environmental Services
777 N. First Street
Suite 450
San Jose, CA 95112
(408) 277-5533 FAX (408) 277-3606
Mr. D. King Boynton (4304)
Standards and Applied Science Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Ms. Maude Bullock (N-457T)
Office of the Chief of
Naval Operations
Crystal Plaza #5 Room 678
2211 Jefferson Davis Hwy.
Arlington, VA 22244-5108
(703) 602-2568 FAX (703) 602-5547
Mr. Tom Brosnan
Bureau of Clean Water
New York City
Dept. of Environ. Protection
Wards Island
New York, NY 10034
(212) 860-9388 FAX (212) 860-9570
Mr. Barry Burgan
U.S. EPA - Office of Water
401 M Street, Sw
Washington, DC 20460
Ms. Debora Brubaker
Chemist Systems Analyst
DynCorp'Viar
300 N. Ixe Street
Alexandria, VA 22314-2695
(703) 519-1382 FAX (703) 684-0610
Mr. John Burkstaller
Boyle Engineering
5845 Onix
Suite 400
El Paso, TX 79912
(915) 581-5902 FAX (915) 581-5372
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Robert Burm (8WMO)
U.S. EPA - Region 8
999-18th Street
Suite 500
Denver, CO 80202
(303) 293-1655 FAX (303) 294-1386
Mr. Ing-Yih (Sam) Cheng
City of Los Angeles
222 N. Sepulveda Blvd.
El Sequendo, CA 90245
(310) 524-8295 FAX (310) 524-8294
Mr. Dennis Cannon
Audiovisual Dept.
Dr. Pornsook Chongprasith
ASEAN-CPMS II
Thailand
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604)986-4331 FAX (604) 662-8548
Mr. Robert F. Cantilli (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401M Street, SW
Washington, DC 20460
Mr. Mike Connor
Massachusetts Water
Resources Authority
100 First Avenue
Boston, MA 02129
(617) 242-6000 FAX (617) 241-6550
Mr. D. Bumell Cavender
Santa Ana Watershed
Project Authority (S AWPA)
11615 Sterling Avenue
Riverside, CA 92503
(909)785-5411 FAX (909) 352-3422
Ms. Marjorie Coombs (4305)
Standards and Applied Science Division
U.S. EPA-Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-9821 FAX (202) 260-9830
. 9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Doug Cox
Audiovisual Dept.
Mr. James Curtis
Water Quality Program
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3610 FAX (410) 633-0456
Ms. Ellen M. Crocker
U.S. General Accounting Office
Ten Causeway Street
Suite 575
Boston, MA 02222
(617) 565-7469 FAX (617) 565-5909
Ms. Paula Dannenfeldt
Assn. of Metropolitan
Sewerage Agencies
1000 Connecticut Avenue, NW
Suite 410
Washington, DC 20036
(202) 833-4654 FAX (202) 833-4657
Mr. Rodney Craze
City of Riverside, California
5950 Acorn Street
Riverside, CA 92504
(909)351-6011 FAX (909) 687-6978
Mr. David G. Davis (4501-F)
U.S. EPA - Office of Wetlands,
Oceans, & Watersheds
401 M Street, SW
Washington, DC 20460
Mr. Ed Curley
Pima County Wastewater
201 N. Stone, 8th Floor
Tucson, AZ 85701 .
(602) 740-6638 FAX (602) 620-0135
Ms. Robin Davis
Labat-Anderson, Inc.
2200 Clarendon Blvd.
Suite 900
Arlington, VA 22201
(800) 832-7828 FAX (703) 525-0201
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Wayne S. Davis
U.S. EPA - Office of Policy,
Planning & Evaluation
401 M Street, SW (2162)
Washington, DC 20460
(202) 260-4906 FAX (202) 260-4903
Ms. Ella Deocadiz
ASEAN-CPMS II
Phillipines
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604)986-4331 FAX (604) 662-8548
Mr. Charles G. Delos (4304)
Health and Ecological Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Ms. Frances A. Desselle (4305)
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202)260-1320 FAX (202) 260-9830
Ms. Beth Delson (4502-F)
U.S. EPA - Wetlands Division
401 M Street, SW
Washington, DC 20460
(202) 260-6071 FAX (202) 260-8000
Mr. Jerome Diamond
Tetra Tech, Inc.
10045 Red Run Blvd.
Owings Mills, MD 21117
(410) 356-8993 FAX (410) 356-9005
Mr. Gregory M. Denton
Division of Water Pollution Control
Tennessee Dept. of
Environ, and Conservation
7th Floor, L & C Annex
401 Church Street
Nashville, TN 37243-1534
(615) 532-0699 FAX (615) 532-0046
Ms. Irene Suzukida Dooley (4203)
U. S. EPA - Permits Division
401 M Street, SW
Washington, DC 20460
(202)260-9531 FAX (202) 260-1460
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Michael C. Dougherty
HQ Marine Corps
2 Navy Annex
Washington, DC 20380-1775
(703) 696-2138 FAX (703) 696-1020
Mr. Tim Dwyer (4203)
U.S. EPA - Permits Division
401 M Street, SW
Washington, DC 20460
(202) 260-6064 FAX (202) 260-1460
Ms. Maureen Driscoll
U.S. General Accounting Office
Ten Causeway Street
Suite 575
Boston, MA 02222
(617) 565-8870 FAX (617) 565-5909
Robin L. Edwards
EMMI Coordinator
DynCorp»Viar
300 N. Lee Street
Alexandria, VA 22314-2695
(703) 519-1200 FAX (703) 684-0610
Mr. Mitch Dubensky
American Forest &
Paper Association
1111- 19th Street, NW
Washington, DC 20036
(202) 463-2434 FAX (202) 463-2423
Mr. Charles Eirkson
Environmental Scientist
U.S. Food & Drug Administration
Center for Veterinary Medicine
7500 Standish Place
Rockville,MD 20855
(301) 594-1683 FAX (301) 594-2297
Ms. Sarelle Dugas
Reedy Creek
Improvement Dist.
2191 Bear Island Road
Lake Buena Vista, FL 32830
(407) 824-7313 FAX (407) 824-7309
Ms. Kelly Eisenman
U.S. EPA
Chesapeake Bay Program
410 Severn Avenue
Annapolis, MD 21403
(410) 267-5728 FAX (410) 267-5777
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Kathryn M. Elliott
Environmental Scientist
Permits & Licensing Dept.
Potomac Electric Power
1900 Pennsylvania Avenue, NW
Washington, DC 20068
(202) 331-6706 FAX (202) 331-6197
Ayo Falusi
Amoco Corporation
200 E. Randolph, MC 4905
Chicago, IL 60601
(312) 856-7570 FAX (312) 616-0152
Mr. Donald Elmore
Water Quality Program
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3610 FAX (410) 633-0456
Mr. Joseph G. Farrell
University of Delaware
Sea Grant
700 Pilottown Road
Lewes, DE 19958
(302) 645-4250 FAX (302) 645-4007
Mr. Mohamed Elnabarawy
3M Company
900 Bush Avenue
Bldg. 21-2W
St. Paul, MN 55144
(612) 778-5151 FAX (612) 778-7203
Mr. Chris Faulkner
U.S. EPA - Office of Wetlands,
Oceans, and Watersheds
401 M Street, SW (4503F)
Washington, DC 20460
(202) 260-6228 FAX (202) 260-1977
Mr. Gary E. Ettel
Louisville & Jefferson Counties
Metro Sewer Dist.
400 S. Sixth Street
Louisville, KY 40202
(502) 540-6957 FAX (502) 966-3887
Ms. Lynn Feldpausch (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
10
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. James Felkel
U.S. EPA
401 M Street, SW (7507)
Washington, DC 20460
(703) 305-5828
Mr. Tom Fink
Audiovisual Dept.
Mr. Bob Fergen
Hazen & Sawyer
4011 West Chase Blvd.
Suite 500
Raleigh, NC 27607
(919) 833-7152 FAX (919) 833-1828
Mr. Matt Fisher
Audiovisual Dept.
Mr. Benjy Picks (4502F)
Program Analyst
U.S. EPA - Office of Wetlands,
Oceans, & Watersheds
401 M Street, SW
Washington, DC 20460
(202) 260-2364 FAX (202) 260-8000
Mr. Frank Foley
Northeast Ohio Regional
Sewer District
4747 E. 49th Street
Cleveland, OH 44125
(216)641-6000 FAX (216) 641-8118
Mr. Robbin Finch
City of Boise, Idaho
Public Works Dept.
P.O. Box 500
Boise, ID 83701
(208) 384-3900 FAX (208) 384-4384
Dr. Jeffery A. Foran
ILSI Risk Science Institute
1126 16th Street, NW
Washington, DC 20036
(202) 659-3306 FAX (202) 659-3617
11
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Laura Gabinski (2137)
U. S. EPA - Offfice of Policy,
Planning, & Evaluation
401M Street, SW
Washington, DC 20460
(202) 260-5868 FAX (202) 260-1935
Ms. Mary Jo Garreis
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3610 FAX (410) 633-0456
Mr. Harold Gano
Olivenhain Municipal
Water District
1966 Olivenhain Road
Encinitas,CA 92024
(619) 753-6466 FAX (619) 753-1578
Ms. Trish Garrigan
U.S. EPA - Region 1
John F. Kennedy Federal Bldg. - WSS
Boston, MA 02203-2211
(617) 565-2987 FAX (617) 565-4940
Ms. Anna Garcia (4201)
U.S. EPA
Office of Water
401 M Street, SW
Washington, DC 20460
(202)260-7840 FAX (202) 260-1156
Mr. Jeroen Gerritsen
Tetra Tech, Inc.
10045 Red Run Blvd.
Suite 110
Owings Mills, MD 21117
(410) 356-8993 FAX (410) 356-9005
Ms. Robin L. Garibay
Advent Group, Inc.
1925 N. Lynn Street
Suite 702
Rosslyn, VA 22071
(703) 522-9662 FAX (703) 522-2416
Mr. Nahil Ghalayini, P.E.
Maryland-National Capital
Park & Planning Commission
8787 Georgia Avenue
Silver Spring, MD 20910-3760
(301)) 595-4546 FAX (301) 495-1303
12
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. George R. Gibson, Jr. (4304)
Health and Ecological Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Normand Goulet
Northern Virginia
Planning Commission
7535 Little River Turnpike
Annandale,VA 22003
(703) 642-0700 FAX (703) 642-5077
Ms. Maria Gomez-Taylor (4304)
Health and Ecological Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Mark B. Graham
Arlington County
2100 Clarendon Blvd.
Suite 801
Arlington, VA 22201
(703) 358-3613 FAX (703) 358-7134
Mr. Bryan Goodwin
Standards and Applied Science Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Ms. Karen Graham
American Planning Association
1776 Massachusetts Avenue, NW
4th Floor
Washington, DC 20036
(202)872-0611 FAX (202) 872-0643
Dr. Frank Gostomski (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-1321
Ms. Sharon Green
County Sanitation Districts
of Los Angeles County
P.O. Box 4998
Whittier,CA 90607
(310)699-7411 FAX (310) 692-5103
13
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Charles N. Gregg
The Nature Conservancy
1815 N.Lynn Street
Arlington, VA 22209
(703) 841-8792 FAX (703) 841-7400
Mr. Donald Grothe
Monsanto Company
800 N. Lindbergh Blvd.
St. Louis, MO 63167
(314) 694-4940 FAX (314) 694-1531
Ms. Jean W. Gregory
Virginia Dept. of
Environmental Qualty
P.O. Box 10009
Richmond, VA 23240-0009
(804) 527-5093 FAX (804) 527-5267
Mr. Tom Grouhoug
Larry Walker Associates
509-4th Street
Davis, CA 95616
(916) 753-6400 FAX (916) 753-7030
Mr. Michael Gritzuk
City of Phoenix, AZ
Water Services Dept.
200 W. Washington Street
Phoenix, AZ 85003
(602) 262-6627 FAX (602) 495-5542
Mr. Patricio Guerrerortiz, P.E.
Water Quality Director
City of Santa Fe
73 Paseo Real
Santa Fe, NM 87501
(505) 474-0650 FAX (505) 474-0677
Ms. Sara Gropen
Attorney/Environmental Engineer
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
(703) 821-4710 FAX (703) 821-4721
Ms. Karen Guglielmone
Brown & Caldwell
7535 E. Hampden Avenue #403
Denver, CO 80231-4838
(303) 750-3983 FAX (303) 750-1912
14
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Dr. Mohammed Habibian
Washington Suburban
Sanitary Commission
14501 SweitzerLane
8th Floor EE&SS
Laurel, MD 20707
(301) 206-8077 FAX (301) 206-8290
Ms. Carol Haley (HFV-152)
U.S. Food & Drug Administration
Center for Veterinary Medicine
7500 Standish Place
Rockville,MD 20855
(301) 594-1682 FAX (301) 594-2297
Mr. Lee Hachigian
Environmental & Energy Staff
General Motors Corp.
485 W. Milwaukee Avenue
Detroit, MI 48202-3220
(313)556-7658
Mr. Will Hall (4203)
U.S. EPA - Permits Division
401 M Street, SW
Washington, DC 20460
(202)260-1458 FAX (202) 260-1460
Mr. Samuel J. Hadeed
Assn. of Metropolitan
Sewerage Agencies
1000 Connecticut Avenue, NW #410
Washington, DC 20036
(202) 833-4655 FAX (202) 833-4657
Mr. Eric P. Hall
WQP
U.S. EPA - Region 1
John F. Kennedy Federal Bldg.
Boston, MA 02203
(617) 565-3533 FAX (617) 565-4940
Ms. Curry Hagerty
American Public
Power Association
2301 M Street, NW
Washington, DC 20037-1484
(202) 467-2930 FAX (202) 467-2910
Ms. Dawn Hamilton
American Oceans Campaign
201 Massachusetts Avenue, NE
Suite C-3
Washington, DC 20002
(202) 544-3526 FAX (202) 544-5625
15
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr.EdHanley
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-6980 FAX (202) 260-6738
Ms. Claire Harrison
Eastern Municipal
Water District
P.O. Box 8300
San Jacinto, CA 92581-8300
(909) 925-7676 x526 FAX (909) 929-0257
Mr. Michael Harrass
Amoco Corporation
200 E. Randolph Drive (MC4902)
Chicago, IL 60601
(312) 856-5116 FAX (312) 856-7584
Mr. James E. Harrison
U.S. EPA - Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-3396 x6638 FAX (404) 347-1799
Mr. Todd Harris
Denver Metro Wastewater
Reclamation District
6450 York Street
Denver, CO 80229-7499
(303) 286-3255 FAX (303) 286-3030
Mr. Richard Healy
U.S. EPA - Standards & Applied
Science Division
401 M Street, SW (4305)
Washington, DC 20460
(202)260-7812 FAX (202) 260-9830
Ms. Pamela J. Harris
U.S. EPA
401 M Street
Washington, DC 20460
(202) 260-8077 FAX (202) 260-1977
Mr. Robert Healy (4304)
Standards and Appliced Science Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
16
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Judy Hecht (4102)
U.S EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202) 260-5682 FAX (202) 260-0587
Mr. John E. Hensel
Minnesota Pollution
Control Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-9315 FAX (612) 297-8683
Mr. Alan Heck
Prince George's County
Health Department
9201 Basil Court
Sutie 318
Landover,MD 20706
(301) 883-7680 FAX (301) 883-7601
Mr. Craig Higgason
U.S. EPA - Region 4
Office of Regional Counsel
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2641
Mr. Ray D. Hedrick
Salt River Project
P.O. Box 52025
Phoenix, AZ 85072-2025
(602) 236-2828 FAX (602) 236-3407
Ms. Patricia K. Hill
American Forest &
Paper Association
1111 19th Street, NW
Suite 800
Washington, DC 20036
(202)463-2581 FAX (202) 463-2423
Mr. Thomas Henry
U.S. EPA - Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-0414 FAX (215) 597-3359
Mr. William Hodgins
Union Camp Corp.
P.O. Box 1391
Savannah, GA 31402
17
9 A 5/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Robert A. Hollander
City of Phoenix
Water Services Dept.
200 W. Washington
Phoenix, AZ 85003
(602) 262-4992 FAX (602) 495-5542
Dr. Malikusworo Hutomo
ASEAN-CPMS II
Indonesia
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604)986-4331 FAX (604) 662-8548
Mr. Bryan Holtrop (4203)
U.S. EPA - Permits Division
401 M Street, SW
Washington, DC 20460
(202) 260-6814 FAX (202) 260-1460
Mr. Lee W. Ingram
Environmental Scientist
Permits & Licensing Dept.
Potomac Electric Power
1900 Pennsylvania Avenue, NW
Washington, DC 20068
(202)872-0389 FAX (202) 331-6197
Mr. John F. Houlihan
U.S. EPA - Region 7
726 Minnesota Avenue
Kansas City.KS 66101
(913) 551-7432 FAX (913) 551-7765
Mr. John E. Jackson
Planning Manager
Unified Sewerage Agency
of Washington County, OR
155 N. First Avenue, M/S 10
Hillsboro, OR 97124
(503) 648-8644 FAX (503) 640-3525
Edythe Humphries, Ph.D.
Wetlands & Subaqueous Lands Section
Dept. of Natural Resources & Envir. Control
Delaware Division of
Water Resources
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
(302) 739-4691 FAX (302) 739-3491
Mr. Joe Jacob
The Nature Conservancy
P.O. Box 2267
Chapel Hill, NC 27515-2267
(919) 967-5493 FAX (919) 967-1575
18
9/15/94
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J
Attendees List
1
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Final Participants' List
Water Quality Criteria and Standards Conferenc^ djx B
Arlington, Virginia
September 13 - 15, 1994
Ms. Jenny Jacobs
Labat-Anderson, Inc.
2200 Clarendon Blvd.
Suite 900
Arlington, VA 22201
(703) 525-0552 FAX (703) 525-0201
Mr. Paul B. Jiapizian
Maryland Dept. of
the Environment
Dennis E. Jelinski, Ph.D.
Institute of Agriculture and Natural Resources
University of Nebraska-Lincoln
101 Plant Industry
P.O. Box 8308114
Lincoln, NE 68583-0814
(402) 472-2944 FAX (402) 472-2964
Mr. Kent Johnson
Asst. Manager, Water Quality
Metropolitan Council
Mears Park Centre
230 E. 5th Street
St. Paul, MN 55101
(612)772-7117
Ms. Carolyn Jenkins
NEIWPCC
255 Ballardvale Street
2nd Floor
Wilmington, MA 01887
(508) 658-0500 FAX (508) 658-5509
Mr. Ron Jones
Texas Institute
for Research
Box T-258
Stephenville, TX 76402
(817)968-9569 FAX (817) 968-9568
Mr. Paul B. Jiapizian
Water Quality Program
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3610 FAX (410) 633-0456
Mr. Steve Jost
Audiovisual Dept.
19
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Ong Kah Sin
ASEAN-CPMS H
Malaysia
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604) 986-4331 FAX (604) 662-8548
Mr.TimKasten(4301)
Policy and Communications Staff
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Mark Kallenbach
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
Mr. Aaron M. Keel
Wetlands Specialist
Nontidal Wetlands and Waterways Division
Maryland Dept. of
Natural Resources
Tawes State Office Bldg.
Annapolis, MD 21401-2397
(410) 974-3841 FAX (410) 974-3907
Mr. Jacques Kapuscinski
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202)260- FAX (202) 260-
Ms. Patricia Keith
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-5678 FAX (202) 260-1036
Mr. Doug Karafa
Clark County, Nevada
Sanitation District
5857 E. Flamingo Road
Las Vegas, NV 89122
(702) 434-6601 FAX (702) 454-5435
Ms. Alison Kerester
American Petroleum
Institute
1220 L Street, NW
Washington, DC 20006
(202) 682-8346 FAX (202) 682-8031
20
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Bernard C. Kersey
City of San Bernardino
Municipal Water Dept.
300 North "D" Street
San Bernardino, CA 92418
(909) 384-5091 FAX (909) 384-5475
Mr. Ken Kirk
Assoc. of Metropolitan
Sewerage Agencies
1000 Connecticut, NW
Washington, DC 20036
(202) 833-4653 FAX (202) 833-4657
Mr. Jerry Kidwell
Ogden Environmental
3211 Jermantown Road
Fairfax, VA
(703)246-0500
Mr. David Klauder
U.S. EPA - Office of .
Research & Development
401 M Street, SW
Washington, DC 20460
(202) 260-0536 FAX (202) 260-0507
Mr. Preston Kinne
Kootenai Tribe of Idaho
P.O. Box 1269
Monastery, ID 83805
(208) 267-3519 FAX (208) 267-2960
Mr. Bob Klepp
Permits Division
U.S. EPA - Office of
Wastewater Management
401 M Street, SW
Washington, DC 20460 '
Ms. Jessica Kinsall
Water Quality Supervisor
DOE-O
TN Dept. of Environment &
Conservation
761 Emory Valley Road
Oak Ridge, TN 37830
(615)481-0995 FAX (615) 482-1835
Ms. Karen Klima (34Q5R)
U.S. EPA
401 M Street, SW
Washington, DC 20460
(703) 235-5590 FAX (703) 557-3186
21
9/15/94
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Final Participants' List
Water Quality Criteria arid Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Karen Klima (3405R)
U.S. EPA
401 M Street, SW
Washington, DC 20460
(703) 235-5590 FAX (703) 557-3186
Ms. Jan Kourmadas
Ogden Environmental
18 Allyssum
Rancho Santo Marg., CA 92688
(714)589-4301 FAX (714) 459-5863
Mr. Melvin Knott
Water Quality Program
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3610 FAX (410) 633-0456
Ms. Rosanna Kroll
Water Quality Program
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410)631-3610 FAX (410) 633-0456
Mr. Monty D. Knudsen
Division of Habitat Conservation
U.S. Fish and Wildlife Service
4401 N.Fairfax Drive
400 Arlington Square
Arlington, VA 22203
(703) 358-2201 FAX (703) 358-2232
Ms. Rosanna Kroll
Maryland Dept. of
the Environment
Ms. Christine Koppel
Water Environment
Federation
601 Wythe Street
Alexandria, VA 22314
(703) 684-2460 FAX (703) 684-2413
Mr. F. Edward Krueger
Senior Project Scientist
Water & Land Programs Dept.
Potomac Electric Power
1900 Pennsylvania Avenue, NW
Washington, DC 20068-0001
(202)331-6539
22
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. James L. Kuhn
Commissioner
Green Bay Metropolitan
Sewerage District
P.O. Box 19015
Green Bay, WI 54307
(414) 432-4893 FAX (414) 432-4302
Mr. Gerald LaVeck (4304)
Standards and Applied Science Division
U.S. EPA-Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Ms. Marcia Lagerloef
U.S. EPA - Region 10
1200 - 6th Avenue
Seattle, WA 98101
(206) 553-0176 FAX (206) 553-0165
Mr. Norman E. LeBlanc
Chief of Technical Services
Hampton Roads
Sanitation District
1436 Air Rail Avenue
Virginia Beach, VA 23455
(804) 460-2261 FAX (804) 460-2372
Ms. Beth Lamoureux
Environmental Contaminants
U.S. Fish and
Wildlife Service
4401 N. Fairfax Drive
Suite 330
Arlington, VA 22203
(703) 358-2148 FAX (703) 358-1800
Ms. Deborah Lebow (4504F)
Oceans Division
U.S. EPA- Office of Water
401 M Street, SW
Washington, DC 20460
(202) 260-6419 FAX (202) 260-9960
Mr. Jeffrey Lape (4203)
U.S. EPA - Office of
Wastewater Management
401 M Street, SW
Washington, DC 20460
(202) 260-5230 FAX (202) 260-1460
Mr. Frederick Leutner
Standards and Applied Science Division
U:S. EPA - Office of
Science and Technology
401 M Street, SW (Mail Stop 4305)
Washington, DC 20460
23
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Bob Linett
SAIC
7600-A Leesburg Pike
Falls Church, Va 22043
(703) 821-4797 FAX (703) 821-4721
Mr. James W. Lund (4304)
Policy and Communications Staff
U.S. EPA - Office of .
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Keith J. Linn
Northeast Ohio Regional
Sewer District
4747 E. 49th Street
Cuyahoga Heights, OH 44125
(216) 641-6000 FAX (216) 641-8118
Mr. Jeffrey S. Lynn
International Paper
6400 Poplar Avenue Tower JJ
Memphis, TN 38197
(901) 763-6721 FAX (901) 763-6939
Mr. Elston Lomax
Audiovisual Dept.
Mr. John Lyons
Ohio River Valley
Water Sanitation Comm.
5735 Kellogg Avenue
Cincinnati, OH 45228
(513) 231-7719
Mr. Dennis J. Long
Malcolm Prinie, Inc.
2603 W. Market Street
Akron, OH 44313
(216) 867-0053 FAX (216) 867-1622
Mr. Morris Mabbitt (4304)
Policy and Communications Staff
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
24
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Martin Maner
Arkansas Dept. of Pollution
Control and Ecology
P.O. Box 8913
Little Rock, AR 72219-8913
(501) 570-2130 FAX (501) 562-0297
Mr. Menchu Martinez (4101)
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202) 260-5700 FAX (202) 260-0587
Ms. Robin Mann
Sierra Club
266 Beechwood Drive
Rosemont,PA 19010
(610) 527-4598
Ms. Beth McGee
North Carolina Division of
Environ. Management
P.O. Box 24535
Raleigh, NC 27626
(919)733-5083 FAX (919) 715-5637
Mr. Ken Manning
Lower Colorado
River Authority
P.O. Box 220
Austin, TX 78767-0220
(800) 776-5272 x7631 FAX (512) 473-4066
Ms. Barbara McLeod
U.S. EPA - Region 5
77 W. Jackson Blvd.
Chicago, IL 60604
(312)886-3718 FAX (312) 886-0957
Ms. Mary Marra
National Wildlife Federation
1400 - 16th Street, NW
Washington, DC 20036
(202) 797-6886 FAX (202) 797-6646
Ms. Sharon Meigs
Prince George's
County Government
9400 Peppercorn Place
Suite 600
Landover, MD 20785
(301) 883-7163 FAX (301) 883-5923
25
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Edmund D. Miller
Department of Defense
DUSD(ES)/CM
400 Army Navy Drive, #206
Arlington, VA 22202-2884
(703) 604-5775 FAX (703) 604-5934
Mr. Mark Montague
American Bottoms Regional
Wastewater Treatment Facility
1 American Bottoms Road
Sauget, IL 62201
(618) 337-1710 FAX (618) 337-8919
Mr. Bruce S. Mintz (4304)
Health and Ecological Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Mark Montague
American Bottoms Regional
Wastewater Treatment Facility
1 American Bottoms Road
Sauget, IL 62201
(618)337-1710 FAX (618) 337-8919
Ms. Paula F. Monroe
U.S. EPA - Office of Wetlands,
Oceans and Watersheds
401 M Street, SW
Washington, DC 20460
(202) 260-6582
Ms. Susan Moore
Environmental Scientist
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
(703) 734-3102 FAX (703) 821-4721
Mr. Jon G. Monson
Public Utilities Director
City of Hollywood, Florida
1715 N. 21st Avenue
P.O. Box 299045
Hollywood, FL 33022
(305) 921-3301 FAX (305) 921-3304
Mr. T.R. "Buddy" Morgan
Montgomery Water Works
& Sanitary Sewer Board
P.O. Box 1631
Montgomery, AL 36102
(205) 240-1604 FAX (205) 240-1616
26
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Ted Morton
American Oceans Campaign
201 Massachusetts Avenue, NE
Suite C-3
Washington, DC 20002
(202) 544-3526 FAX (202) 544-5625
Ms. Deborah G. Nagle (4203)
Permits Division
U.S. EPA - Office of
Wastewater Management
401 M Street, SW
Washington, DC 20460
(202) 260-2656 FAX (202) 260-1460
Mr. James Moye
Water Policy Report
1225 Jefferson Davis Highway
Arlington, VA 22202
(703) 416-8564 FAX (703) 416-8543
Mr. Jim Nemke
Madison Metropolitan
Sewerage District
1610 Moorland Road
Madison, WI 53713
(608) 222-1201 x276
FAX (608) 222-2703
Ms. Ruth Much
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
(703) 734-2572
Mr. William K. Norris
Technical Resources
International, Inc.
3202 Tower Oaks Blvd.
Rockville,MD 20852
(301)231-5250 FAX (301) 231-6377
Ms. Deirdre Murphy
Water Quality Program
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3610 FAX (410) 633-0456
Mr. Douglas J. Norton (4503F)
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202) 260-7017 FAX (202) 260-7024
27
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Angela Nugent (2127)
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-5871 FAX (202) 260-1935
Ms. Carolyn Hardy Olsen
Brown & Caldwell
53 Perimeter Center East
Suite 500
Atlanta, GA 30306
(404) 344-2997 FAX (404) 396-9495
Mr. Thomas P. O'FarreU (4304)
Engineering and Analysis Division
U.S. EPA - Office of
Science and Technology
401M Street, SW
Washington, DC 20460
Mr. David E. Ortman
Friends of the Earth
4512 University Way, NE
Seattle, WA 98105
(206) 633-1661
Mr. Robert Oberthaler
New Jersey DEP
Office of Land & Water Planning
401 E. State Street
Trenton, NJ 08625
(609) 633-1179 FAX (609) 984-2147
Mr. Ray T. Ofvin, Jr.
Western Carolina Regional
Sewer Authority
561 Mauldin Road
Greenville, SC 29607
(803) 299-4014 FAX (803) 277-5852
Mr. Ernest Ochsner
Prairie Plains Resource Institute
Fidelity Bldg.
Aurora, NE 68818
(402) 694-6045
Mr. Bob Overly
James River Corp.
P.O. Box 23790
Green Bay, WI 54305-3790
(414) 433-6177 FAX (414) 431-6877
28
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Cheryl Overstreet (6W-QT)
U.S. EPA - Region 6
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-6643 FAX (214) 665-6689
Mr. Kamlesh Parekh
Office of Engineering Services
DC Dept. of Public Works
5000 Overlook Avenue
Washington, DC 20032
(202) 645-6277 FAX (202) 645-6245
Mr. Bill Painter (2124)
U.S. EPA - Office of Policy,
Planning, and Evaluation
Waterside Mall
401 M Street, SW
Washington, DC 20460
(202) 260-5484 FAX (202) 260-2300
Ms. Sharon Fancy Parrish
U.S. EPA - Region 6
1445 Ross Avenue
Dallas, TX 75044
(214)665-7145 FAX (214) 665-6689
Mr. Bill Painter
U.S. EPA
Mr. Yogendra Patel (4304)
Health and Ecological Criteria Division
U.S. EPA-Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Ms. Karen L. Pallansch
Alexandria Sanitation
Authority
P.O. Box 1987
Alexandria, VA 22313
(703) 549-3381 FAX (703) 519-9023
Mr. Nilesh M. Patel (4304)
Engineering and Analysis Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
29
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Karen Pelto
MA Dept. of Fisheries, Wildlife,
& Envir. Law Enforcement
100 Cambridge Street
Room 1901
Boston, MA 02202
(617) 727-1614 x359 FAX (617) 727-2566
Mr. David Pfeifer
U.S. EPA - Region 5
77 W. Jackson Blvd.
Chicago, IL 60604
(312) 353-9024 FAX (312) 886-7804
Ms. Sandra Perrin
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202) 260-7382 FAX (202) 260-1827
Mr. David W. Pierce
Chevron
100 Chevron Way
Richmond, CA 94802-0627
(510)242-4875 FAX (510) 242-5577
Mr. Jerry Pesch
U.S. EPA - Environmental
Research Lab
Narragansett, RI 02882
(401) 782-3007 FAX (401) 782-3030
Mr. Mark T. Pifher
Anderson, Gianunzio,
Dude, Pifher
104 S. Cascade Avenue
Suite 204
Colorado Springs, CO 80903
(719) 632-3545 FAX (719) 632-5452
Ms. Betty Peterson
Seminar Coordinator
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
(703) 734-3101 FAX (703) 821-4721
Mr. Dave Pincumbe
U.S. EPA - Region 1
John F. Kennedy Federal Bldg.
Boston, MA 02132
(617) 565-3544 FAX (617) 565-4940
30
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Marjorie Pitts (4304)
Standards and Ap[plied Science Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Gerald C. Potamis
Water Division
U.S. EPA - Region 1
John F. Kennedy Federal Building
Boston, MA 02203
(617)565-3575 FAX (617) 565-4940
Ms. MaryPlatt
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-2276 FAX (202) 260-5394
Mr. Kennard Potts (4304)
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-7893 FAX (202) 260-1036
Mr. Jim Pletl
Hampton Roads
Sanitation District
1436 Air Rail Avenue
P.O. Box 5911
Virginia Beach, VA 23455
(804) 460-2261 FAX (804) 460-2372
Ms. Elizabeth Power
ASEAN-CPMS II
Canada
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604)986-4331 FAX (604) 662-8548
Ms. Arleen A. Plunkett (4304)
Policy and Communications Staff
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Ms. Theresa Pugh
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
(202) 682-8036 FAX (202) 682-8031
31
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Ira S. Rackley
Kennedy/Jenks Consultants
5190 Neil Road
Suite 300
Reno.NV 89502
(702) 827-7900 FAX (702) 827-7925
Ms. Dianne Reid
North Carolina Dept. of
Environ. Management
P.O. Box 29535
Raleigh, NC 27626-0535
(919) 733-5083 x568 FAX (919) 715-5637
Mr. Beverly Randolph (4304)
Policy and Communications Staff
U.S. EPA - Office of
Science and Technology
401M Street, SW
Washington, DC 20460
Mr. Andrew L. Richardson
Government of DC
Preventive Health Services Administration
613 G Street, NW
Washington, DC
Mr. Randall Ransom
Dow Corning Corp.
3901 S. Saginaw
Midland, MI 48686-0995
(517) 496-5644 FAX (517) 496-5419
Ms. Lynn Riddick
Dyn Corp Viar
300 N. Lee Street
Alexandria, VA 22314
(703) 519-1380 FAX (703) 684-0610
Mr. Kenneth Ratliff
Health, Environment & Safety
Phillips Petroleum Co.
13 Cl Phillips Building
Barflesville, OK 74004
(918) 661-1063 FAX (918) 661-5664
Mr. Jack D. Riessen
Iowa Dept. of
Natural Resources
Wallace State Office Bldg. »
DesMoines,IA 50319
(515) 281-5029 FAX (515) 281-8895
32
9/15/94
Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Doreen Robb (4502-F)
U.S. EPA - Wetlands Division
401 M Street, SW
Washington, DC 20460
(202) 260-1906 FAX (202) 260-8000
Ms. Karen Rothstein (1199)
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202)260-7519 FAX (202) 260-7509
Ms. Anne Robertsqn
U.S. EPA
401 M Street, SW (4501F)
Washington, DC 20460
(202)260-9112
Ms. Christine Ruf
U.S. EPA - Office of Policy,
Planning, and Evaluation
Waterside Mall
401 M Street, SW
Washington, DC 20460
(202) 260-5484 FAX (202) 260-2300
Ms. Concepcion Rodriguez
U.S. EPA - OPP
401 M Street, SW (7507C)
Washington, DC 20460
(703) 308-2805
Mr. Peter Ruffier
City of Eugene, Oregon
410 River Avenue
Eugene, OR 97404
(503) 984-8600 FAX (503) 984-8601
Ms. Nancy Roth (4502F)
U.S. EPA - Wetlands Division
401 M Street, SW
Washington, DC 20460
(202) 260-5299 FAX (202) 260-8000
Mr. Hal Runke
Barr Engineering Co.
8300 Norman Center Drive
Suite 300
Minneapolis, MN 55437-1026
(612) 832-2804 FAX (612) 832-2601
33
9/15/94-
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Richard Sachs
Green Bay Metropolitan
Sewerage District
P.O. Box 19015
Green Bay, WI 54307
(414) 432-4893 FAX (414) 432-4302
Mr. Eugene J. Scarpulla
City of Baltimore - Reservoir
Natural Resources Office
5685 Oakland Road
Eldersburg, MD 21784-6828
(410) 795-6151 FAX (410) 549-9327
Mr. Joel Salter
U.S. EPA - Office of Wetlands,
Oceans, and Watersheds
401 M Street, SW
Washington, DC 20460
(202) 260-8484 FAX (202) 260-9960
Ms. Elaine Schaeffer
County of Fairfax
9399 Richmond Highway
P.O. Box 268
Lorton, VA 22199
(703) 550-9740 x319 FAX (703) 339-5070
Mr. Doug Samson
The Nature Conservancy
(301) 656-8673
Mr. Greg Schaner
Assoc. of Metropolitan
Sewerage Agencies
1000 Connecticut Avenue, NW
Washington, DC 20036
(202) 833-9106 FAX (202) 833-4657
Ms. Jackie Savitz
Chesapeake Bay Foundation
164 Conduit Street
Annapolis, MD 21401
(410) 268-8833 FAX (410) 280-3513
Ms. Kari Schank
Labat-Anderson, Inc.
2200 Clarendon Blvd.
Suite 900
Arlington, VA 22201
(703) 525-0553 FAX (703) 525-0201
34
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Stephen Schaub (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
Mr. Ronald F. Scott
City of Columbus
Sewerage & Drainage
1250 Fairwood Avenue
Columbus, OH 43206-3372
(614) 645-7429 FAX (614) 645-8893
Mr. Daniel Schechter
Water Environment Federation
601 Wythe Street
Alexandria, VA 22314
(703) 684-2423 FAX (703) 684-2492
Mr. Greg Searle
Wisconsin Dept. of
Natural Resources
P.O. Box 7921
Madison, WI 53707
(608) 266-0156 FAX (608) 267-2800
Mr. Lee Schroer (2355)
Water Division
U.S. EPA-Office of
General Counsel
401 M Street, SW
511 West Tower
Washington, DC 20460
FAX (202) 260-7702
Salvador J. Sedita, Ph.D.
Head, Biology Section
Metropolitan Water Reclamation
District of Greater Chicago
6001 W. Pershing Road
Cicero, IL 60650
(708) 222-4074 FAX (708) 780-6706
Mr. Richard F. Schwer
DuPont Company
1007 Market Street
Wilmington, DE 19898
(302) 774-8024 FAX (302) 774-8110
Ms. Martha Segall
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
(703) 821-4874
35
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Dr. Tang Seung Mun
ASEAN-CPMS H
Singapore
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604) 986-4331 FAX (604) 662-8548
Mr. JayantB. Shah
USAF- HQ
Environ. Quality Directorate
1260 Air Force
Room 50376 - Pentagon
Washington, DC 20330-1260
(703) 697-3360 FAX (703) 697-3378
Mr. Michael Sevener
Washington Suburban
Sanitary Commission
14501 Sweitzer Lane
8th Floor EE&SS
Laurel, MD 20707
(301) 206-8284 FAX (301) 206-8290
Mr. Larry J. Shepard
U.S. EPA - Region 7
726 Minnesota Avenue
Kansas City, KS 64101
(913) 551-7441 FAX (913) 551-7765
Ms. Janeen Shaffer
Assoc. of State & Interstate
Water Pollution Control Authorities
750 - 1st Street, NE
Suite 910
Washington, DC 20002
(202) 898-0905 FAX (202) 898-0929
Mr. James A. Shuster
Program Management Branch
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202)260-5829 FAX (202) 260-1827
Ms. Gwen Shaffer
Water Policy Report
1225 Jefferson Davis Highway
Arlington, VA 22202
(703) 416-8964 FAX (703) 416-8543
Ms. Ellen Siegler
American Petroleum Institute
1220 "L" Street, NW
Washington, DC 20005
(202) 682-8271 FAX (202) 682-8033
36
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. John Simons (4602)
U.S. EPA - Ground Water
Protection Division
401 M Street, SW
Washington, DC 20460
(202) 260-7091 FAX (202) 260-0732
Mr. Jim Siriano
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
(703) 734-4380
Shon Simpson
Oklahoma Water
Resources Board
600 N. Harvey
Oklahoma City, OK 73101
(405)231-2541 FAX (405) 231-2600
Ms. Jennifer Smith
Prince George's
County Government
9400 Peppercorn Place
Suite 600
Landover, MD 20785
(301) 883-7169 FAX (301) 883-5923
Mr. Ganjindar Singh
DCRA
Water Management Div.
2100 Martin Luther King, Jr. Avenue, SE
#203
Washington, DC 20020
(202) 645-6601 x3037 FAX (202) 645-6622
Mr. Tony Smith
Permits Division
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202)260-1017 FAX (202) 260-1460
Mr. Timothy J. Sinnott
New York Dept. of
Environmental Conservation
50 Wolf Road
Room 530
Albany, NY 12233-4756
(518) 456-1769 FAX (518) 485-8424
Ms. Aileen Smith
SCS Engineers
11260 Roger Bacon Drive
Reston, VA 22090
(703)471-6150 FAX (703) 471-6676
37
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Derek Smithee
Oklahoma Water
Resources Board
600 N. Harvey
Oklahoma City, OK 73101
(405) 231-2541 FAX (405) 231-2600
Mr. Bob Spehar
U.S. EPA
Environmental Research Lab
6201 Congdon Blvd.
Duluth, MN 55804
(218) 720-5564 FAX (218) 720-5539
Mr. C.S. Sodmi
Chehalis Indian Tribe
P.O. Box 536
Oakville, WA 98568
(206) 273-5911 FAX (206) 273-7558
Maj. Jeffery Springer, P.E.
Compliance Division
U.S. Army - Environmental
Programs Directorate
HQDAATTN: DAEvl-ED-C
0600 Army Pentagon
Washington, DC 20310-0600
(703) 696-8078 FAX (703) 696-8088
Dr. Tong Soo Loong
ASEAN-CPMS H
Malaysia
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604) 986-4331 FAX (604) 662-8548
Ms. Bernita Starks
U.S. EPA
401 M Street, SW
Washington, DC 20460
(202) 260-7287
Mr. Mark T. Southerland
Versar, Inc.
9200 Rumsey Road
Columbia, MD 21045
(410) 964-9200 FAX (410) 964-5156
Mr. Raffael Stein (4304)
Engineering and Analysis Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
38
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Joseph J. Stepun
Western Lake Superior
Sanitary District
2626 Courtland Street
Duluth, MN 55806
(218) 722-3336 x214 FAX (218) 727-7471
Mr. Mark Symborski
Prince George's
County Government
9400 Peppercorn Place
Landover, MD 20785
(301) 883-7165 FAX (301) 883-5923
Mr. James Stine
Baltimore Gas & Electric
7609 Energy Parkway
Suite 101
Baltimore, MD 21226
(410) 787-6649 FAX (410) 787-5199
Prakasam Tata, Ph.D.
Coordinator of Research
Metropolitan Water Reclamation
District of Greater Chicago
6001 W. Pershing Road
Cicero, IL 60650
(708) 222-4059 FAX (708) 780-6706
Mr. Philip Swamp
Environment Division
St. Regis Mohawk Tribe
Box 8A Route 37
Hogansburg, NY 13655
(518)358-3141 FAX (518) 358-2797
Ms. Stephanie Taylor
EPA Wetlands Information Hotline
Labat-Anderson, Inc.
2200 Clarendon Blvd.
Suite 900
Arlington, VA 22201
(703) 525-0203 FAX (703) 525-0201
Mr. Joseph Sylvester
U.S. EPA - EFED
Arlington, VA
(703) 305-7463
Mr. Peter Tennant
Ohio River Valley
Water Sanitation Comm.
5735 Kellogg Avenue
Cincinnati, OH 45228
(513)231-7719
39
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Cassondra Thomas
Technical Resources, Inc.
3202 Tower Oaks Blvd.
Rockville,MD 20852
(301)231-5250 FAX (301) 231-6377
Mr. Dave W. Tucker
City of San Jose,
California
700 Los Enteros
San Jose, CA 95134
(408) 945-5300 FAX (408) 945-5442
Mr. Paul J. Traina
Camp, Dresser & McKee, Inc.
P.O. Box 1121
Tucker, GA 30084
(404) 934-5251 FAX (404) 934-5251
Mr. Gary Ullinskey
City of Phoenix
200 W. Washington Street
9th Floor
Phoenix, AZ 85003
(602) 534-1360 FAX (602) 495-5542
Mr. Robert W. Troxler
Asst. Director
Gwinnett County Dept. of
Public Utilities
75 Langley Drive
Lawrenceville, GA 30245
(404) 822-7365 FAX (404) 822-7170
Mr. George Utting (4203)
U.S. EPA - Permits Division
401 M Street, SW
Washington, DC 20460
Ms. Theresa Tuano (4503F)
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202)260-7059 FAX (202) 260-7024
Ms. Valerie Uyeda
Unocal Corp.
1201 W. 5th Street
Los Angeles, CA 90017
(213) 977-6073 FAX (213) 977-6364
40
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Charles P. Vanderlyn (4204)
U.S. EPA - Office of
Wastewater Management
401 M Street, SW
Washington, DC 20460
(202) 260-7277 FAX (202) 260-0116
Mr. Fritz Wagener
U.S. EPA - Region 4
345 Courtland Street
Atlanta, GA 30365
(404) 347-3555 x6655
FAX (404) 347-1799
Ms. Edna Villanueva (4504F)
U.S. EPA - Office of Water
401 M Street, SW
Washington, DC 20460
(202) 260-6059 FAX (202) 260-9960
Ms. Mary V. Waldron
SAIC
7600-ALeesburgPike
Falls Church, VA 22043
(703) 734-3124
Mr. Burnell Vincent (8105)
U.S. EPA - Office of Research
and Development
401 M Street, SW
Washington, DC 20460
(202) 260-0591 FAX (202) 260-6932
Mr. Thomas P. Walters, P.E.
Vice President & Regional Water Svcs. Mgr.
CH2MHill
2567 Fairlane Drive
P.O. Box 230548
Montgomery, AL 36123-0548
(205)271-1444 FAX (205) 277-5763
Ms. Ching Volpp
New Jersey DEP
401 E. State Street
Trenton, NJ 08625
(609)633-1179 FAX (609) 984-2147
Ms. Sherry H. Wang
Dept. of Environ, and Conservation
Tennessee Division of
Water Pollution Control
7th Floor, L & C Annex
401 Church Street
Nashville, TN 37243-1534
(615) 532-0699 FAX (615) 532-0046
41
9/15/94
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Final Participants' List
/••
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Kevin G. Wanttaja
Salt River Project
P.O. Box 52025, PAB 352
Phoenix, AZ 85072-2025
(602) 236-2968 FAX (602) 236-3407
Mr. Robert Weaver
Kelly & Weaver
HDupont Circle
Suite 700
Washington, DC 20036
(202)797-7100 FAX (202) 939-6969
Ms. Leslie Warner
DuPont Agricultural Products
P.O. Box 80038
Wilmington, DE 19880-0038
(302) 992-2880 FAX (302) 992-6470
Mr. David Webb
Wisconsin Dept. of
Natural Resources
P.O. Box 7921
Madison, WI 53707
(608) 264-6260 FAX (608) 267-2800
Ms. Marsha Waters
Tennessee Dept. of
Environ, and Conservation
761 Emory Valley Road
Oak Ridge, TN 37830
(615) 481-0995 FAX (615) 482-1835
Mr. Daniel Weese (4203)
Permits Division
U.S. EPA - Office of
Wastewater Management
401 M Street, SW
Washington, DC 20460
(202) 260-6809 FAX (202) 260-1460
Mr. Dwight Watson
ASEAN-CPMSII
Canada
195 Pemberton Avenue
North Vancouver, BC Canada, V7P 2R4
(604) 986-4331 FAX (604) 662-8548
Mr. Neil Weinstein
Rust Environmental &
Infrastructure
11240 Waples Mill Road
Fairfax, VA 22030
(703) 385-3566 FAX (703) 385-8319
42
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Betty West (4203)
U.S. EPA - OWM
Storm Water Section
401 M Street, SW
Washington, DC 20460
(202) 260-8486
Ms. Marian Whiteman
Sidley & Austin
One First National Bank
Chicago, IL 60603
(312) 853-4572 FAX (312) 853-7036
Ms. Norma K. Whetzel (4304)
Health and Ecological Criteria Division
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-1313 FAX (202) 260-1036
Molly Whitworth, Ph.D. (2124)
U.S. EPA - Office of Policy,
Planning, and Evaluation
Waterside Mall
401 M Street, SW
Washington, DC 20460
(202) 260-5484 FAX (202) 260-2300
Ms. Charlotte White
U.S. EPA - Office of Policy,
Planning, and Evaluation
401 M Street, SW
Waterside Mall
Washington, DC 20460
(202) 260-5484 FAX (202) 260-2300
Mr. Robert Wichter
Richmond Dept. of
Public Utilities
600 E. Broad Street
Room 821
Richmond, VA 23219
(804) 780-5183 FAX (804) 649-9661
Ms. Carmelita White (4203)
U.S. EPA - Office of
Wastewater Management
401 M Street, Sw
Washington, DC 20460
Mr. Ron Wicks
Water Quality Program
Maryland Dept. of
the Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3610 FAX (410) 633-0456
43
9/15/94
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Final Participants' List
Water Quality Criteria a.nd Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Linda B. Wilbur (4301)
Budget and Program Management Staff
U.S. EPA - Office of
Science and Technology
401 M Street, SW
Washington, DC 20460
(202) 260-5392 FAX (202) 260-5394
Ms. Laura Wolf
Brown McCarroll &
Oaks Hartline
1400 Franklin Plaza
111 Congress Avenue
Austin, TX 78701
(512)472-5456 FAX (512) 479-1101
Ms. Sarah Williamson
Coastal Resources Inc.
110 Annapolis Street
Annapolis, MD 21401
(410) 268-1268 FAX (410) 268-0140
Mr. David Wolf
U~S EPA
1550 Wilson Blvd.
Rosslyn,VA 22209
(703)235-5592 FAX (702) 557-3186
Mr. Erik L. Winchester
Dames & Moore
7101 Wisconsin Avenue
Bethesda,MD 20814
(301) 652-2215 FAX (301) 652-6717
Mr. Rob Wood
U.S. EPA - Office of
Wastewater Management
401 M Street, SW
Room NE2104A
Washington, DC 20460
(202) 260-9536
Ms. Carol Winston
SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
(703) 821-4639 FAX (703) 821-4721
Mr. Philip C. Woods (W-3-2)
U.S. EPA - Region 9
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 744-1997 FAX (415) 744-1078
44
9/15/94
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Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Ms. Jennifer Wurzbacher
Hunton & Williams
2000 Pennsylvania, NW
#9000
Washington, DC 20006
(202) 778-2243 FAX (202) 778-2201
Mr. Carl Young
U.S. EPA - Region 6
1445 Ross Avenue
Dallas, TK 75202
(214) 655-6645 FAX (214) 655-6689
Ms. Gerri Wyer
Wyer Management Associates
P.O. Box 1310
10275 Little Skyline Drive
Orange, VA 22960
(703) 672-2221 FAX (703) 672-9201
Mr. Andy Zepp
The Nature Conservancy
350 Alexander Street
Rochester, NY 14604
(716) 546-8030 FAX (716) 546-7825
Mr. LaRue Wyrick
Pennsylvania Dept. of
Environ. Resources
400 Market Street
10th Floor
Harrisburg, PA 17105-8465
(717)787-9637 FAX (717) 772-5156
Mr. Rick Zeroka
Massachusetts Coastal
Zone Management
100 Cambridge Street
20th Floor
Boston, MA 02202
(617) 727-9530 x422 FAX (617) 727-2754
Ms. Carey Yates
Ogden Environmental
DoD/DEOM
200 Stovall Street
Room 12549
Alexandria, VA 22332-2300
(703) 325-0002 FAX (703) 325-6777
Ms. Eve M. Zimmerman
U.S. EPA - Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-3396 x6637 FAX (404) 347-1799
45
9/15/94
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r
Final Participants' List
Water Quality Criteria and Standards Conference
Arlington, Virginia
September 13 - 15, 1994
Mr. Bob Zimmerman
Administrator
Delaware Division of
Water Resources
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
(302)739-5726 FAX (302) 739-3491
flU.S. GOVERNMENT PRINTING OFFICE: 1995-615-003-01089
46
9/15/94
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