WATER QUALITY 2000 Phase II Report Problem Identification September 1990 ------- NOTICE This report was approved by a straw vote of the organizations participating in the Water Quality 2000 Member Congress, held September 12-14,1990, in An- napolis, Maryland. It is now being circulated to all member organizations for ratification. For more information, contact Water Quality 2000,601 Wythe Street, Alexandria, VA 22314-1994, (703) 684-2418. ------- Table of Contents FOREWORD iii EXECUTIVE SUMMARY iv Sources of Impairment iv The Condition of the Nation's Waters and Aquatic Habitat vi Causes of Water Quality Problems viii Impediments to Solutions ix Looking Forward Toward Phase HI Solutions x I. WATER QUALITY CONDITIONS IN 1990 1 Sources and Effects of Impaired Water Resources 3 Measurements of Progress Toward Clean Water Goals 6 The condition of surface waters 7 The condition of groundwater 11 The condition of aquatic resources 13 Measurement of Commitment to Gean Water Programs 14 Investments in water pollution control 14 Services delivered 15 Numbers of trained water quality professionals 16 Public awareness of water quality issues 17 Growth in the number of water quality institutions 18 Conclusion 18 II. THE ROOT CAUSES OF WATER QUALITY PROBLEMS 19 Societal Causes of Water Quality Impairment 20 How we live 21 How we produce and consume 22 How we farm 24 How we transport people and goods 25 How we plan 27 How we have acted in the past 28 Conclusion 29 HI. IMPEDIMENTS TO IMPROVING WATER QUALITY 30 Narrowly Focused Water Policy 30 Watershed-based planning 31 Cross-media effects 32 The relationship between water quantity and water quality 33 Pollutant prevention 33 Environmental results 35 Institutional Conflicts 36 Federal government 36 State government 37 Local government 38 ------- The private sector 39 Citizens'organizations 40 Legislative and Regulatory Overlaps, Conflicts, and Gaps 40 Overlapping statutory or regulatory controls 41 Conflicting policies and programs 42 Gaps in authority 43 Insufficient Funding and Incentives for Water Quality Improvement 45 Inadequate Attention to the Need for Trained Personnel 47 Limitations on Research and Development 49 Inadequate Public Commitment to Water Resource Quality 51 Conclusion 53 IV. WATER QUALITY CHALLENGES FOR THE FUTURE 54 Preventing Pollution 54 Controlling Runoff from Urban and Rural Lands 55 Focusing on Toxic Constituents 56 Protecting Aquatic Ecosystems 56 Coping with Multi-media Pollution 57 Protecting Groundwater 57 Increasing Scientific Understanding of Water Quality Issues 58 Promoting Wise Use of Resourcese 58 Setting Priorities 59 Providing Safe Drinking Water 60 Managing Growth and Development 61 Financing Water Resource Improvements 61 V. THE NEXT STEP 63 NOTES 64 APPENDIX A Organization, Goal, and Mission of Water Quality 2000 69 APPENDIX B Member Organizations 72 APPENDDCC Steering Committee Members and Their Affiliations 74 APPENDIX D Work Group Participants 75 APPENDIX E Water Quality 2000 Vision Statement and Goal 82 APPENDDCF Summaries of Work Group Reports 83 APPENDIX G Major Milestones in Federal Water Quality Legislation 118 ------- FOREWORD This report is a starting point in that it identifies problems without considering solutions. The phased approach of Hater Quality 2000—which proceeds from problem identification to discussion of solutions to public outreach—allows for fully informed debate that considers all interests and points of view. However, this approach also poses some risk. Phase II is limited to identifying water quality problems without considering solutions. This does not imply, however, that solutions do not exist, or that we should fail to give credit to the substantial progress that has been made. Readers should rather consider this document as merely the first half of a two-part report. It has been developed and adopted in the recognition that a common understanding of these problems among all parties will facilitate a unified approach to formulating solutions during Phase III. While all the problems discussed in this report are important, some are more severe than others. Despite the risk of leaving readers with the impression that all problems are equal, this report does not attempt to assign priorities. Phase III will include additional consideration of which problems should receive priority for action. To assist in this effort, readers are encouraged to provide Water Quality 2000 with their views about the severity and relative priority of the problems identified here. Comments should be sent to Paul Woodruff (chairman of the Water Quality 2000 Steering Committee), Water Quality 2000, 601 Wythe Street, Alexandria, VA 22314-1994, (703) 684-2418. September 1990 Page iii ------- EXECUTIVE SUMMARY Water Quality 2000—a consortium of more than 80 public, private, and nonprofit organizations—began a four-phase effort in 1988 to develop and implement an integrated national policy for water quality. This policy for protection and enhancement of U.S. waterbodies ultimately supports Water Quality 2000's goal—a society living in harmony with healthy natural systems. This report completes Phase II, the identification of problems. Phase III will focus on solutions, and Phase IV will begin the implementation process by transmitting recommendations to the Congress and all who influence water quality. A complete description of the processes by which Water Quality 2000 was organized and now conducts its deliberations is presented in Appendix A. Based on the reports of ten work groups, which brought together hundreds of water quality experts, Water Quality 2000 has concluded that today's water quality problems stem from a variety of human activities and that the public policies and programs currently in place are not sufficient to deal with them. While significant progress has been made to improve the condition of the nation's fresh and marine waters, the national interim goal of "fishable and swimmable" waters has not been attained in many areas. Moreover, much work is needed to achieve the broader, overall objectives of a wide range of water legislation including the broad objective of the Clean Water Act—to restore and maintain the chemical, physical, and biological integrity of the nation's surface waters. SOURCES OF IMPAIRMENT Degradation (pollution) of the nation's water resource results from direct human activity, such as municipal or industrial discharges of wastewaters, and from indirect actions, such as land alteration for farming, forestry, mining, transportation, or development. Sources of impairment vary from location to location and among surface waters, ground waters, and aquatic resources. Yet overall, the following sources (listed alphabetically) contribute significantly to impairment in many locations and ecosystems: o Agriculture Agricultural runoff is the source of impairment of 55 percent of surveyed river miles found to be September 1990 Page iv ------- impaired and 58 percent of surveyed lake acres. Runoff includes large volumes of sediment and nutrients and smaller amounts of more acutely toxic pollutants, such as pesticides. Agricultural chemicals are significant sources of groundwater contamination, and animal production is a major source of phosphorus and pathogens in lakes. Agriculture also accounts for wetlands losses and damage to riparian and floodplain environments. o Community Wastewater While publicly owned treatment works (POTWs) remove many pollutants from community wastewater, these facilities nonetheless are the points of entry of remaining pollutants into the nation's waters. In addition to continuing on-going efforts to improve the operation and maintenance of these facilities, communities face the following problems: the control of pollution from combined sewer overflows, stormwater, and nonpoint sources; the control of toxic pollutants from industrial, residential, and other sources; and the upgrading of existing facilities and construction of new ones to control nutrients, pathogens, and other pollutants. o Deposition of Atmospheric Contaminants Aerial transport of acidic compounds, toxics such as PCBs, and nitrates, degrade fresh and marine waters and impair the health of ecosystems in several parts of the U.S. Sources include utilities, industry, motor vehicles, and agricultural practices. o Industry The manufacturing, service, power generating, and solid and hazardous waste management sectors discharge toxics and other contaminants, produce runoff, and contribute airborne contaminants; and releases of waste heat. o Land Alteration A wide variety of land uses—including logging, mining, road building, and development (especially September 1990 Page v ------- urban and suburban sprawl)—contribute to runoff of water, soil, and chemicals used in and on the land. These activities also degrade or destroy essential aquatic resources such as wetlands and riparian areas and the fauna and flora that depend on them. o Stocking and Harvest Intentional and accidental introduction of exotics and overharvesting of fish and shellfish resources often result in irreversible impacts on aquatic ecosystems. o Transportation Major sources of impairment from transportation activities include shipping, surface transport, and pipelines; spills and other discharges of oil and other substances; runoff from transportation facilities; destruction of wetlands and other aquatic resources from dredging and building transportation works; and air emissions. o Urban Runoff Urban runoff is a major source of water pollutants. Municipal and industrial stormwater remains largely unregulated. Residuals of chemicals applied to suburban lawns may ultimately find their way to surface and ground waters. o Water Projects By removing physical habitat and water required by aquatic species, channelization, dams, and consumptive use of water are implicated in the extinction of many species. Dams and their resultant reservoirs have been particularly troublesome for anadromous and riverine species, respectively. THE CONDITION OF THE NATION'S WATERS AND AQUATIC HABITAT Neither the quality of the nation's waters nor the health of ecosystems is measured regularly. Current ambient monitoring of the chemistry and biology of waters and aquatic resources is far too September 1990 Page vj ------- limited to be of use in assessing the performance of water programs. Moreover, data on the release of contaminants to surface and ground waters are incomplete, covering only a fraction of all waters and, typically, a small number of pollutants. The lack of such fundamental measures of progress toward cleaner water leads to conflicting reports on the condition of water quality and aquatic ecosystems. Yet, we can see the results of water quality programs in the return of game fish to rivers once thought incapable of supporting fisheries. Evidence indicates that progress is being made. Although designated uses allow for a wide variety of water quality, some waters now enjoy sufficient quality to support the uses specified by the states. At the same time, there are failures of programs: when surface and ground waters are reported as contaminated or unfit for use as intended, when aquatic habitat is destroyed as a result of land development and other activities, or when contaminant advisories are necessary because the harvestable fish are unsafe for human consumption. While contamination of surface waters from toxic chemicals is thought to be more localized than from other sources such as siltation, nutrients, or organic matter, local impacts on public health and aquatic life can be severe where toxics have accumulated or continue to be discharged. In general, the nation has not fully measured the prevalence of toxics in the environment, fully studied routes of exposure, or sufficiently understood levels of concern. The high cost of monitoring for toxics and conducting health effects studies partly explains this situation. Comprehensive data on the quality of groundwater is not collected routinely. Working from anecdotal reports and one-time surveys, however, it is probably reasonable to conclude that the shallowest aquifers are at greatest risk of contamination from human activities, especially those aquifers where the overlying soil is thin and permeable. Contamination of shallow aquifers results from agricultural sources such as pesticides, animal waste, or nitrates from the application of fertilizers, and from industrial or other sources such as synthetic organic chemicals, leaky underground storage tanks, and spills. As yet, most deeper aquifers are believed to be relatively free from contamination. However, a survey conducted by EPA shows that about 20 percent of all drinking water aquifers (shallow and deep) are contaminated to some degree by man-made chemicals.1 Wetlands are not only important breeding and nursery grounds for aquatic life but also have an important function in improving water quality, recharging groundwater, flood control, recreation, September 1990 Page vii ------- fish and wildlife habitat, shoreline protection, and water storage. These resources are being rapidly destroyed by a variety of human activities. CAUSES OF WATER QUALITY PROBLEMS The fundamental causes of water quality problems lie in seemingly unrelated aspects of life: the way we farm, produce, consume, transport people and goods, and plan for the future. Many aspects of modern life and past practices put pressure on water quality. Until recently, these activities proceeded with little recognition of the degradation they caused in surface waters, groundwater, or aquatic habitats. Typically, individuals and society as a whole make choices that reflect values specific to living, producing, consuming, or working—but not necessarily to achieving clean water. Sometimes these values conflict with water quality goals. Until very recently, conflicts remained largely unrecognized, at least until water quality problems became so apparent that the public demanded action, as it did in the early 1970s in response to the Cuyahoga River catching fire, or in the 1980s to the declining condition of the Chesapeake Bay. Historically, such conflicts were resolved through relatively narrow legislation to restore and protect water quality by altering the direct sources of impairment but not necessarily the forces underlying polluting behavior. Even today, when we are beginning to recognize some of the basic conflicts between human activities and environmental quality, few contemporary solutions address the basic economic and social forces at the root of water problems. Governmental water quality programs and policies are part of the problem to the degree that they do not fully address these societal causes of impairment. Hence, while it may take time to reconcile societal values regarding the way we live, produce, consume, farm, or work with our preference for a healthy environment, drawing attention to the effects of our societal decisions on water quality is critical. Whether or not Water Quality 2000's goal for the nation can be achieved will be determined, in large part, by whether we can reshape these societal functions in ways that are compatible with protecting and enhancing water quality and aquatic ecosystems. September 1990 Page viii ------- IMPEDIMENTS TO SOLUTIONS Societal factors in conflict with a healthy environment produce serious, long-term impediments to improved water quality. In the near term, however, opportunities exist to address impediments posed by current water policies and programs. The work group reports consistently raised the following types of impediments: o Narrowly focused water policies impede the holistic solutions that address watershed-based planning, cross-media effects, the connection between water quantity and water quality, incentives for pollution prevention, and management for environmental results. o Conflicts among water quality institutions impede collaborative solutions in which all levels of government, the private sector, and individuals participate according to their strengths and limitations. o Legislative and regulatory overlaps, conflicts, and gaps sometimes create inefficient or ineffective solutions to water problems or may result in the underprotection of water quality or water-based natural resources. o Inadequate funding and ineffective economic incentives for clean water programs and construction, operation, and maintenance of facilities impedes progress toward national goals and is out of touch with general public opinion and actual need. o Inadequate attention to the need for trained personnel has created a serious gap between a limited supply of new and retrained professionals and a growing demand for their skills. o Current research and development programs fail to meet the challenge presented by the complexity of today's water quality problems and the need to improve our basic scientific understanding of ecosystems. o Inadequate communication has resulted in citizens who are largely unaware of the linkages between daily life and September 1990 Page ix ------- water resources, what they can do to improve the quality of water and aquatic habitat, or why they should participate in the first place. LOOKING FORWARD TOWARD PHASE III SOLUTIONS The results of public and private efforts to control sources of water pollutants and generally improve the quality of waters and aquatic habitats over the years have been mixed. Some problems have been solved, others await the results of programs only recently put in place, while still others remain challenges for the future. One of foremost challenges we face is to move the debate over water quality toward the root causes of degradation in water resources presented in this paper. In practice, this means thinking more carefully about how to pursue societal goals for living, working, farming, and producing in ways that are consistent with improving the quality of the nation's waters. Water Quality 2000 identified the following 12 issues that merit consideration in Phase III of our work: o Preventing pollution, o Controlling runoff from urban and rural lands, o Focusing on toxic constituents, o Protecting aquatic ecosystems, o Coping with multi-media pollution, o Protecting groundwater, o Increasing scientific understanding of water quality issues, o Promoting wise use of resources, o Setting priorities, o Providing safe drinking water, September 1990 Page x ------- o Managing growth and development, and o Financing water resource improvements. We feel confident that this report presents a balanced description of today's water quality problems, their causes, and the impediments to solutions. We are optimistic that these conclusions will stand as a sound foundation upon which to formulate solutions in the next phase of our work. We eagerly look forward to Phase III of our project and extend an invitation to all who wish to contribute to the debate over solutions to comment on this report. September 1990 Page ri ------- I. WATER QUALITY CONDITIONS IN 1990 The effects of water pollution on human health and natural systems were first acknowledged in the U.S. as a societal problem in the 18th century. Major urban centers began to deal with this problem by installing sewers shortly thereafter. The construction of wastewater treatment facilities followed in the 19th century. Water quality legislation has been in place in many states since early in this century. By 1970, the nation could point to over $70 billion in municipal wastewater treatment assets and almost $80 billion in water supply system assets. These facilities provided three-quarters of the population with sewage collection, two-thirds of the population with at least primary treatment, and about half the population with secondary treatment.2 About 85 percent of the U.S. population was served by centralized water supply. Also by 1970, state regulation resulting in about $10 billion a year in private investment in pollution control facilities addressed the problem of industrial discharge, at least to some degree.3 While the federal interest in water quality was established as early as 1899 (See Appendix G: Major Milestones in Federal Water Quality Legislation), the basis for today's federal program was established in 1972. In that year, Congress passed amendments to the Federal Water Pollution Control Act (FWPCA), which together with subsequent amendments is now commonly called the Clean Water Act. The Act had an ambitious objective—to restore and maintain the chemical, physical, and biological integrity of the nation's waters. As interim goals, the Act called for eliminating discharges of pollutants into navigable waters and achieving fishable and swimmable conditions. September 1990 Page 1 ------- OBJECTIVE AND GOALS OF THE CLEAN WATER ACT (1972 Federal Water Pollution Control Act) The Clean Water Act instituted broad federal authority over all public waters and set as its objective: o To restore and maintain the chemical, physical, and biological integrity of the nation's waters. o Consistent with its other provisions, the Clean Water Act established two interim goals: (1) eliminating the discharge of pollutants into navigable waters by 1985 (the zero discharge goal), and (2) achieving, wherever attainable, a water quality that protects fish, shellfish, and wildlife and provides for recreation in and on the water (the fishable and swixnmable goal). In practice, the zero discharge goal is implemented with respect to point sources principally through a program of technology-based effluent guidelines, standards, and permits that require the elimination of discharges of pollutants where technologically and economically achievable. Stricter controls have been imposed where needed to meet water quality goals. See Appendix G for a more complete list of major federal legislation that affects water quality and aquatic resources. September 1990 rage Z ------- Since refocusing national clean water programs in 1972, the U.S. has enjoyed nearly two decades of governmental, private, and individual attention to water quality protection. Under federal legislation, public and private responsibilities for protecting water quality have shifted over time, as have statutory priorities for action. An even longer history of state statutory action also has contributed to shifts in public and private roles. Many factors have influenced these shifts, including the advance of scientific knowledge, the degree of public awareness of water quality problems, resource limitations, and the availability of pollution control technologies. Much progress has been made, but much more remains to be done. SOURCES AND EFFECTS OF IMPAIRED WATER RESOURCES Five years after the 1985 "zero discharge" goal of the Clean Water Act, and despite the Act's national policy of "no toxics in toxic amounts," we continue to release large quantities of toxics and other pollutants into the nation's surface and ground waters from a variety of sources. The 1983 goal of "fishable and swimmable water" remains equally elusive. While many waters have improved since 1972, some have deteriorated and others have barely kept even. The failure to meet these interim goals means that the overriding objective of the Clean Water Act—to restore and maintain the chemical, physical, and biological integrity of the nation's waters—has not been met for a large percentage of our surface waters. It also results from our overall failure to protect rivers as rivers, lakes as lakes, and estuaries as estuaries. By focusing only on chemical water quality, we ignore the overall health of the biological system. Consequently, we build right up to the water's edge, remove essential coastal and riparian vegetation and other habitat, and channelize and alter the course of our natural waterways. Natural diversity and aquatic productivity is lost as a result. The principal sources of impairment include (in alphabetical order): o Agriculture Agricultural runoff is the source of impairment of 55 percent of surveyed river miles found to be impaired and 58 percent of surveyed lake acres.4 Runoff from September 1990 Page 3 ------- agricultural lands includes large volumes of sediment and nutrients and smaller amounts of more acutely toxic pollutants, such as pesticides. Agricultural chemicals are significant sources of groundwater contamination, as well, and animal production is a major source of phosphorus and pathogens in lakes. Agriculture also accounts for wetlands losses and damage to riparian and floodplain environments. o Community Wastewater While community treatment plants remove many pollutants from domestic and industrial sewage, these facilities nonetheless are the points of entry of pollutants into the nation's waters. In addition to continuing on-going efforts to improve the operation and maintenance of these facilities, communities face the following problems: the control of pollution from combined sewer overflows, stormwater, and nonpoint sources; the control of toxic pollutants from industrial, residential, and other sources; and the upgrading existing facilities and construction of new ones to control nutrients, pathogens, and other pollutants. o Deposition of Atmospheric Contaminants Aerial transport of acidic compounds and other toxic substances has been identified as a major problem affecting lakes and estuaries in several parts of the U.S. Acidification of lakes and streams is directly lethal to aquatic organisms. Deposition of airborne nitrates degrades estuary water quality, causes algal blooms, and impairs healthy ecosystems. Atmospheric sources of PCBs and other toxics are of concern in the Great Lakes, marine waters, and estuaries. o Industry Although more than 90 percent of major industrial dischargers are in compliance with their discharge permits, according to EPA's 1987 Toxic Release Inventory (TRI), manufacturing sources alone continue to discharge an estimated 360 million pounds of toxic pollutants per year into rivers, lakes, and coastal waters, and another 570 million pounds into sewage treatment plants.5 Non-manufacturing sources, such as power-generating September 1990 Page 4 ------- utilities (nuclear, fossil fuel, and hydro), solid and hazardous waste treaters, mining, and others, also contribute significant additional amounts of toxic, radioactive, thermal, and other pollutants. o Land Alteration A wide variety of land uses—including logging, mining, grazing, road building, and development (especially urban and suburban sprawl)—contribute to runoff of water, soil, and chemicals used in and on the land. These activities also degrade or destroy essential aquatic resources such as wetlands, headwater streams, and riparian areas, and the fauna and flora that depend on them. o Stocking and Harvest Intentional and accidental introduction of exotics and overharvesting of fish and shellfish resources often result in irreversible impacts on aquatic ecosystems. o Transportation Major sources include spills and other discharges of oil and other substances from ships, surface transportation, and pipelines; runoff from transportation facilities; destruction of wetlands and other aquatic resources from dredging navigation channels and building transportation works; and emissions. More than 10,000 oil spills release 15 to 20 million gallons of oil into the nation's waters each year. o Urban Runoff Contaminated runoff continues as a major source of water pollutants. Municipal and industrial stormwater remain largely unregulated. Residuals of chemicals applied to suburban lawns may ultimately find their way to surface and ground waters. o Water Projects By removing physical habitat and water required by aquatic species, channelization, dams, and consumptive use of water are implicated in the extinction of many species. Dams and their resultant reservoirs have been September 1990 Page 5 ------- particularly troublesome for anadromous and riverine species, respectively. Water quality is impaired not only by current activities but by past actions that have altered the aquatic regime or have resulted in on-going releases after the productive activity has ceased. Polluted water and lost habitat can pose real problems for human health and the environment. The abundance, diversity, and structure of natural fish and wildlife populations may be impaired, while commercial, sport, and subsistence fisheries and shellfish beds may show reduced productivity. Food and water supplies can be contaminated and waters rendered unsafe for swimming or other recreational uses. An important part of our national and natural heritage in clean water has already been lost, and the balance is under stress. MEASUREMENTS OF PROGRESS TOWARD CLEAN WATER GOALS Ideally, to measure progress of clean water programs nationally, investigators would have access to regularly collected data on physical, chemical, and biological conditions in fresh and marine waters, groundwater, and aquatic habitats. But since only limited data exist, various proxy measurements must be used as substitutes. The reports that states make to EPA every two years on their progress toward meeting the Clean Water Act's two interim goals are the major direct sources of information. Despite their shortcomings, these 305(b) reports (filed to comply with that section of the Act) represent the latest available accounts of the extent to which U.S. waters are meeting the goals of the Clean Water Act. These reports, however, are somewhat limited. For example, waterbodies can be reported as meeting uses under very different criteria across states. Reports often include an unrepresentative sample of all U.S. waterbodies and generally measure ambient concentrations of conventional as opposed to toxic constituents. Data are gathered only from the water column, not the sediment below, or from aquatic life. This practice limits our understanding of accumulation of pollutants in the sediment, in fish, and in other organisms. In addition, this approach limits our understanding of the complex ecological impacts of other factors (habitat degradation, flow alteration, species interactions, and others) that degrade the quality of water resources. Lack of September 1990 Page 6 ------- carefully formulated biological monitoring programs impairs our ability to evaluate environmental results of management actions. Because of the shortcomings of the 305(b) reports, this Phase II Report also presents a wide variety of proxy, or indirect measures, such as the amount invested in water quality control programs, population served by water quality protection facilities, pounds of pollutants removed from effluents, the degree of public concern over water quality issues, numbers of trained water quality professionals, or numbers of water quality institutions. These proxies represent several different perspectives on progress toward building national capacity to address future water quality goals. A summary of current sources of impairment to water quality for all types of waters is presented in Table 1. Sources for entries in this table include the reports of Water Quality 2000's work groups. The Condition of Surface Waters Despite significant progress, the national interim fishable and swimmable goal has not been attained for all waters. Many of the nation's waterways and aquatic ecosystems continue to be affected by contaminants from a variety of human sources, including industry, municipalities, agriculture, and urban runoff. Without adequate data on trends in water quality, it remains difficult to draw clear conclusions on our progress. In fact, two conclusions appear equally valid. Some observers characterize progress since 1970 primarily as a holding action. They believe that clean water programs have mainly prevented further degradation of the nation's surface waters in the face of growing pressures from economic expansion and population growth. But without the national effort to improve water quality, others argue, waterbodies would be much worse off today than 20 years ago because population and economic output have grown by 25 percent and 50 percent, respectively. Our gains are reduced discharges of pollutants on a per capita basis and per dollar of economic output. But the population and GNP of the nation has grown—by 25 percent and 50 percent, respectively, between 1970 and 1988—so because of growth, we may be just keeping even on a total loading basis, with the result that water quality improvement is not universal. September 1990 Page 7 ------- TABLE 1 PRINCIPAL SOURCES OF IMPAIRMENT IN U.S. WATERS AND AQUATIC RESOURCES RESOURCE PRINCIPAL SOURl OF IMPAIRMENT Surface Water (river, lakes, streams marine and estuarine waters) Groundwater (shallow and deep aquifers) o Silt, nutrients, and pesticides from agricultural practices o Pathogens, organic material, nutrients, and toxics from community wastewater o Toxic and heated discharges from industrial sources o Pathogens and nutrients from livestock o Pathogens, organic matter, and toxics from storm sewers and combined sewer overflows o Silt and other pollutants from land alteration, resource extraction, and stream channelization o Spills and other discharges of oil and other substances from transportation activities o Natural leaching of metals, solids, salts, and radon o Toxic metals and organics from leaking underground storage tanks, waste disposal sites, and landfills o Percolation of water containing pathogens, nitrogen, and pesticides from on-site septic systems and agricultural practices o Underground injection of industrial and resource extraction waste Aquatic Resources (wetlands, riparian areas, and aquatic habitat) o Losses and degradation as a result of agricultural practices such as over- grazing o Losses and commercial and industrial development and transportation activities o Siltation as a result of land clearing, resource extraction, and construction o Losses from damming, channelization, and shoreline protection o Species introductions and overharvest September 1990 Page 8 ------- Fresh Waters. On a streaxn-by-stream basis, efforts to measure progress toward clean water have been limited. The latest annual EPA survey (1988) suggests that many waterbodies have been cleaned up, but others have degraded.6 Lake Erie, apparently doomed to death in the 1950s, is alive and improving today. Yet despite improved conditions from the control of conventional pollutants, the lake still has significant toxic contamination problems. The International Joint Commission has identified eight Areas of Concern in Lake Erie and its tributaries, fish consumption advisories are in effect because of contaminants, and the biological community has been drastically altered from its historic condition. The Potomac River, once an unfishable disgrace, is now populated by numerous species of game fish and is a proud attraction for tourists and residents of Washington, D.C. Yet there are also numerous fish consumption advisories, based on contaminants, in effect for the Potomac River. There are two interpretations of the 1988 state reports that addressed the quality of water in 29 percent of the nation's river miles. Viewed one way, progress has been commendable. Of the waters measured, 70 percent fully supported designated uses, such as swimming, drinking, or boating.7 Another 20 percent supported some, but not all of their designated uses. Only 10 percent of assessed river miles did not support any of their designated uses. Viewed another way, there may be less to be encouraged about. That is, supporting uses does not mean that waterbodies are pristine, nor are the conclusions drawn from this relatively limited sample necessarily appropriate for river water quality nationwide. A designation of "not meeting uses" can mean slightly polluted or severely polluted. Moreover, states are inconsistent in the criteria they use to determine if a river section is or is not meeting designated uses. Causes of impairment—silt, nutrients, organics, toxics, pathogens, and so on—are not and cannot always be related to sources of impairment, such as agriculture, industry, or urban runoff. Typically, EPA and state reports measure water quality in the water column and not in the bottom sediment or in fish. Again typically, many factors affecting water resources, including most toxic contaminants, are not measured at all. A more statistically robust analysis concluded that 49 percent of stream segments studied were impaired by degradation in physical habitat conditions.8 Physical habitat impairment is the leading cause of extinction in North American fishes.9 The principal cause of identified pollution in rivers and streams was silt and nutrients —about 42 percent and 26 percent, September 1990 Page 9 ------- respectively, of the river miles assessed in 1988 were so impaired. Pathogens were the cause in nearly 20 percent of impaired miles and organic enrichment was the cause in another 15 percent. Runoff from agricultural lands was the source of 55 percent of the total impairment. Municipal point sources accounted for impairment in about 16 percent of river miles assessed; resource extraction and habitat modifications affected 14 percent each. As noted above, however, these data may be seriously skewed by the absence of comprehensive monitoring for toxics in water, fish and shellfish, and the sediment. The remaining sources—silviculture, industry, construction, land disposal, and combined sewers—affected less than 10 percent each. Assessments of lake acres indicated a similar percentage of impaired waters. Of the 41 percent of lake acres assessed, 74 percent supported designated uses, 16 percent partially supported uses, and 10 percent failed to support uses. Again, nutrients accounted for about half the impaired lake acres. Other causes included siltation (25 percent), organic enrichment (25 percent), salinity (14 percent), and habitat modification (11 percent) . Other causes—pathogens, organics, suspended solids, metals, and pesticides—accounted for less than 10 percent each. Storm sewers accounted for roughly another 35 percent. By far, the most prevalent source of pollution in lakes was agriculture, accounting for nearly 60 percent of impaired lakes acres. Other important sources included habitat modification (33 percent), storm sewers (28 percent), land disposal (24 percent), and municipal point sources (15 percent). Other sources, including industrial point sources, resource extraction, construction, silviculture, and combined sewer overflows, each accounted for less than 10 percent. Marine Waters. It is difficult to accurately assess the extent of impairment of estuarine and coastal waters because the ultimate indicator—the biological community—has not been adequately monitored. However, numerous estuaries have been identified as critically threatened ecosystems and the majority of estuaries and many coastal waters are clearly deteriorating. Municipal point sources—with unspecified contributions of pollutants such as nutrients, pathogens, organic enrichment, and toxics—caused the majority (over 50 percent) of identified impairment in estuaries. In contrast, municipal sources accounted for a smaller proportion of the impairment of rivers, streams, and lakes. Resource extraction caused 34 percent and storm sewers 28 September 1990 Page 10 ------- percent of impaired estuarine square miles. Pollutants from agricultural runoff affected only about 20 percent of estuary square miles assessed. The contribution of pollutants from rivers is also important, but difficult to quantify. Intentional and accidental discharges of oil and other materials from shipping and boating also contributed to marine pollution. Fish consumption advisories are in effect in many coastal areas (such as for large bluefish taken off New Jersey because of PCBs), and several fisheries have been depleted (for example, California sardines, Georges Bank groundfish, redfish in the Gulf of Mexico). The Condition of Groundwater While most groundwater is not currently tapped for drinking because of high salinity, it is the source of drinking water for half the U.S. community drinking water systems (somewhat less than half the population, however) and 95 percent of rural households. Until recently, groundwater was generally assumed to be pristine. We now know that in many areas groundwater has been contaminated by many human activities. Potential sources of contamination attributable to human activity include hazardous and solid waste landfills, petroleum and chemical transportation and storage, septic systems, and the application of pesticides and fertilizer to crops and lawns. In addition, vast quantities of groundwater are naturally degraded from metals, solids, and other constituents that leach from surrounding geologic formations. Groundwater is found in saturated rock, sand, and other geologic formations called aquifers. It is part of the earth's hydrologic cycle, receiving inputs from rain percolating (seeping) downward through the soil and exchanging water with rivers and lakes. Generally, groundwater moves very slowly, but it can sometimes flow swiftly and unpredictably. Because of these characteristics, protecting groundwater poses special challenges. Contamination is difficult to detect and predict; concentrations of contaminants can be high in one place and absent a few feet away. Contaminants can travel slowly or rapidly, evenly or erratically, and cleanup once groundwater is contaminated is difficult if at all possible, expensive, and time-consuming. Contaminated groundwater can pollute streams, wetlands, and estuaries. September 1990 Page 11 ------- There are no comprehensive national accounts of the current condition of groundwater. Despite these constraints, the U.S. Geological Survey, the EPA, and other agencies have conducted a number of groundwater assessments, from which a partial profile of groundwater quality emerges. The highlights of one recent assessment follow.10 o High concentrations of a variety of toxic metals, organic chemicals, and petroleum products form plumes around point sources such as leaking underground storage tanks, waste disposal sites, and landfills. Although the volume of contaminated water in such plumes is relatively small, tens of thousands of such sites exist. These types of problems are, in many cases, a result of past practices and are concentrated in urban or industrialized areas, although they are also found in rural areas. o Some contamination is the result of natural leaching of constituents from soils. Common natural problems include concentrations of dissolved solids, sulfate, iron, and manganese that exceed drinking water standards. In some western locations, natural concentrations of nitrate exceed primary drinking water standards—levels of purity for drinking water determined to be safe under the Safe Drinking Water Act. o In some regions, contaminants derived from runoff are frequently present in shallow wells scattered throughout an area. Where detected, contaminant concentrations generally are at minimum detectable levels, although in a small percentage of water samples, contaminants (such as nitrates and pesticides) exceed drinking water standards or health advisories. Such runoff is associated with densely populated urban areas, agricultural lands, and concentrations of septic systems in suburban areas. Thus, shallow groundwater contamination is often related to land use. o The shallowest aquifers are at greatest risk of contamination, especially those where the overlying unsaturated zone is thin and permeable. Contamination by nitrates and synthetic organic chemicals of shallow aquifers is widespread in many areas. For example, 20 September 1990 Page 12 ------- percent of 124,000 wells analyzed over 25 years had nitrate contamination attributable to fertilizer application, septic systems, or animal wastes. As yet, most deep aquifers are believed to be relatively free from contamination. Yet a recent EPA survey showed that about 20 percent of all drinking water aquifers (shallow and deep) are contaminated to some degree by man-made chemicals.11 One or more of 47 pesticides that can be attributed to normal agricultural use have been detected in groundwater in 26 states. The Condition of Aquatic Resources Aquatic resources include wetlands, riparian (shore) habitat, floodplains, aquatic habitat, and the plant and animal communities that inhabit these areas.12 Aquatic resources have been degraded and destroyed by a broad range of human activities. To date, more than half of the inland and coastal wetlands in the contiguous U.S. have been destroyed, with 10 states losing 70 percent or more of their original acreage.13 Agriculture is by far the major cause of wetland loss. Urbanization, tree harvesting, and grazing have also altered the integrity of aquatic resources. Damming, channelization, mining, thermal effects on biota, and water consumption have further altered and eliminated aquatic habitat and restricted major fisheries. Fish and wildlife may be affected when aquatic habitats are degraded. For example, nearly one-third of North American fish taxa are now at risk of extinction.14 Dams on the Columbia River blocked access to 50 percent of the basin's headwaters for anadromous fish, causing an estimated loss equal to 75 to 80 percent of the annual catch.15 Thirty-eight states, in actions attributable to contamination, have advised against the consumption of certain fishes or have restricted or closed sport fishing in some areas.16 In some areas, disposal of waste and other by-products of human activities has led to contamination of the water column, sediment, fish, and shellfish by bacteria, viruses, and toxics. State reporting on the status of wetlands in 1988 was sparse and uneven; only about one-fourth of the states made reports.17 Incomplete reporting can be traced to the complexity and expense ------- of wetland monitoring, the lack of a complete database on wetland acreage, the absence of state water quality standards for wetlands (on which measures of supporting uses could be based) , and inconsistent national guidance on the type of information to collect. Further, no efforts are made to report on the status and trends of other aquatic habitats, many of which have experienced widespread degradation, or to demonstrate successful environmental results of management programs. MEASUREMENT OF COMMITMENT TO CLEAN WATER PROGRAMS The 305 (b) reports just discussed make up the most direct data on water quality progress. However, several indirect measures also provide valuable perspectives. Most of these indicators measure our national commitment to water quality rather than conditions in bodies of water. Nonetheless, they serve as useful indicators of our current efforts to control pollution and of national capacity to address these goals in the future. Investments in Water Pollution Control As a nation, the U.S. spends more on pollution control per capita and more per unit of economic output than most other industrialized nations including Great Britain, Japan, Canada, or Germany.18 All levels of government (federal, state, local, and special districts) and industry have reported to the Bureau of the Census that they have spent $239 billion to build capital facilities for water pollution control and another $234 billion to operate facilities and administer water pollution control programs since 1970 (1986 dollars).19 Much more may have been spent on water pollution control, but not recorded in Census surveys. For example, water quality is the principal beneficiary of much of what is spent under the Superfund and Resource Conservation and Recovery Act (RCRA) programs. Many industries, such as mining or construction, invest millions in controlling runoff from sites, but these expenditures are probably not recorded in standard surveys of water pollution control expenses. The assessment of need for additional investment in water quality is somewhat variable, as it responds to changes in government regulation, improvements in control technologies and September 1990 Page 14 ------- strategies, and shifts in public attitudes about how much spending is acceptable and how clean is clean. Yet in certain areas, well-documented estimates exist that indicate a need to invest substantial sums. EPA's 1988 Needs Survey, for example, concludes that another $84 billion will have to be spent on municipal wastewater treatment systems to serve the projected population in the year 2008 to comply with the requirements of the Clean Water Act.20 This figure could easily double if communities choose to invest in the control of urban runoff, combined sewer overflows, and rehabilitation of current facilities. Moreover, these figures exclude needed upgrades to comply with the toxic discharge requirements of the 1987 amendments to the Clean Water Act. Implementation of remedial action plans in critical areas of the Great Lakes or restoration plans in the nation's estuaries will increase estimates of need, as well. EPA's work to implement Section 304(m) of the Clean Water Act indicates that effluent guidelines and standards must be revised or developed for many industries. These new requirements are expected to result in significant new private investment in water pollution controls. In 1987, local governments spent about $15 billion to build and operate drinking water systems. By the year 2000, they will have to spend nearly $22 billion a year just to maintain the current levels of service and water purity. Compliance with new standards of water purity under the 1986 amendments to the Safe Drinking Water Act will cost local governments another $500 million a year by the year 2000.21 State water agencies have estimated that, by the mid-1990s, they will have to spend between $300 million a year and $400 million a year more than they now spend to administer water quality and drinking water programs.22 Services Delivered The total population served by central sewers and secondary treatment of wastewater or better has increased by 76 percent, from 85 million in 1972 to 150 million in 1988.a Federal construction grants plus state and local shares built some 4,000 sewer systems and 2,000 treatment plants between 1972 and 1988.2* By 1988, less than 1 percent of the urban population routinely generated and discharged wastewater to waterbodies without any treatment. September 1990 Page IS ------- In the 1980s, EPA and the states had a considerable backlog in issuing wastewater permits to major industrial dischargers. Now, the backlogs appear to be shrinking. Today only about 13 percent of major dischargers await renewed permits.25 The figures for minor dischargers whose effluents individually (but not necessarily collectively) have less effect on the environment are somewhat less encouraging, however (32 percent backlog). As of December 1988, 93 percent of major industrial dischargers and 87 percent of major municipal facilities reported, from the results of their own discharge monitoring, that they were largely meeting their effluent limits. Existing permits, however, do not always cover the full range of pollutants discharged nor do they always protect biotic integrity. Drinking water is provided to 200 million Americans (80 percent of the population) by 60,000 community water systems. Another 140,000 small-scale suppliers deliver drinking water to nonresidential locations such as campgrounds, schools, and factories. Forty million Americans are served by individual drinking water wells. Numbers of Trained Water Quality Professionals Separate statistics are not available on the number of water quality professionals, as distinct from all engineers, life scientists, or social scientists.26 Yet intuition would suggest that their numbers have grown in tandem with increased budgets for water programs and the resultant increase in the number of state, regional, and local water quality institutions. Some data do support such intuition. For example, the employment rate for scientists and engineers, in general, has increased faster than total U.S. employment, accounting for 3.6 percent of the labor force in 1986, compared to 2.4 percent a decade earlier.27 Compared to the Bureau of Labor Statistics* projection of 15 percent average growth in employment in the 1990s, the outlook for professionals that typically manage water quality appears bright: 17 percent growth for civil engineers, 26 percent for biologists, 17 percent for chemists, and 32 percent for managers in the natural sciences.28 The number of certified operators of water and wastewater treatment plants increased rapidly in the 1970s and 1980s. In 1961, there were only about 20,000 certified operators of water and wastewater treatment facilities.29 By 1970, the number of board-certified water and wastewater treatment plant operators had September 1990 Page 16 ------- almost tripled to 57,000. The total almost tripled again by 1980, with 141,700 that year.30 A new survey in 1990 is expected to show that growth in the number of certified operators has leveled off. Public Awareness of Water Quality Issues By many measures, public awareness of the environment is at an all-time high. In a major public opinion poll conducted for USA Today's special Earth Day coverage, for example, Americans were found to be more concerned about the environment today than in the past. Two-thirds of the 850 adults contacted nationwide believed that the environment is getting worse, and one-third saw evidence of local environmental deterioration. While public opinion is heavily influenced by current events, one important finding of this survey was that nearly three-quarters of the respondents were more concerned about these trends than they were five years ago. In another recent survey of 1,500 adults nationwide, 22 percent of respondents said they thought most groundwater is contaminated with chemicals or other pollutants. Only 7 percent were so convinced when that same question was asked in 1981. 3Z Topping the list of environmental concerns in the USA Today poll were two prime water quality issues: storage of hazardous waste and pollution of drinking water, sixty-seven percent of those interviewed said they were "very worried" about hazardous waste; 57 percent were "very worried" about contaminated drinking water. These issues were found to be of greater public concern than increasing cancer rates, running out of landfill space, damage to the ozone layer, the loss of tropical rain forests, or damage from acid rain. Of particular interest, the poll generally corroborated the results of similar efforts in the past — that Americans are more concerned about environmental quality than they are about the cost or inconvenience of new environmental regulations. As one indication, nearly two-thirds of all those polled said they would pay 15 percent higher taxes to clean up the environment. More than half said they were willing to pay 15 percent more for groceries if all packaging was recyclable. At the same time, respondents were not convinced that drastic action was necessary. Two-thirds believed that individuals alone could help the environment significantly. More than half said that the environment can be kept clean without drastic changes in their lifestyles. September 1990 ------- Growth in the Number of Water Quality Institutions Increases in statutory authority and public and private investment in water quality have been accompanied by growth in the number of water quality institutions. This includes local, state, and federal agencies; university research centers; corporate environmental programs; and other public and private entities. One indicator of the growth in water quality institutions is the growth in special districts established to deliver drinking water and wastewater treatment services to the public. In the 1950s and 1960s, there were few such districts; by 1972, however, a total of 6,742 had been established.33 The number of water and sewer districts grew by 50 percent over the next five years to a total of 9,386 by 1977. Growth continued over the following five years, but at a slower pace; by 1982, 10,866 water and sewer districts had been established. CONCUOSION While progress has been made over the past 20 years, a consensus has emerged that we still have a long way to go to solve the nation's water quality problems. If efforts are not expanded to meet these challenges, not only will we fail to meet national water quality goals, we risk a reversal of the progress made to date. September 1990 Page 18 ------- II. THE ROOT CAUSES OF WATER QUALITY PROBLEMS The fundamental causes of water quality problems lie in seemingly unrelated aspects of life: how we live, the way we farm, produce and consume, transport people and goods, and plan for the future. Many aspects of modern life and past practices put pressure on water quality. Until recently, these activities proceeded with little recognition of the effects they had on surface water, groundwater, and aquatic habitats. Typically, individuals and society make choices that reflect values specific to farming, producing, consuming, or working—but not necessarily to achieving clean water or healthy ecosystems. Sometimes these values conflict with clean water goals, until very recently, conflicts remained largely unrecognized, at least until water quality problems became so apparent that the public demanded action, as it did in the early 1970s in response to the Cuyahoga River catching fire, or in the 1980s to the declining condition of the Chesapeake Bay. Historically, such conflicts were resolved through relatively narrow legislation to restore and protect water quality by altering the direct sources of impairment but not necessarily the root causes of declining water resource quality. Even today, when we are beginning to recognize some of the basic conflicts between human activities and environmental quality, few contemporary solutions address the basic economic and social forces at the root of water problems. Our tendency as a society is to underestimate the cost of pollution in currently less populated areas, such as wilderness or aquifer recharge areas, because there are fewer immediately measurable impacts on human health and because we tend to undervalue the impacts on biological communities and their habitats. We are beginning to recognize the inadequacies in currently available methods to assess the negative consequences and benefits of our actions. The economic benefits of pollution may be reaped by one group, whereas the costs of pollution may be borne disproportionately by another—those least financially and politically capable of influencing the decisions. Hence, while it may take time to reconcile societal values regarding the way we live, produce and consume, farm, or work with our preference for a healthy environment, drawing attention to the effects of our societal decisions on water quality is critical. Focusing on these societal causes of water quality problems is September 1990 Page 19 ------- essential if we are to articulate long-term solutions in which societal goals are compatible with clean water. SOCIETAL CAUSES OF WATER QUALITY IMPAIRMENT People's day-to-day activities and the choices they make for lifestyles—suburban living, green lawns, and throw-away consumer goods—can have unanticipated but profound effects on water quality. Similarly, our business and government leaders have, at times, made decisions with little regard for water quality impacts. Intensive agriculture seeking high yields with fertilizers, pesticides, and irrigation water is designed to feed the nation at low cost. Until recently, the cost of water quality impairment from chemicals and soil washing off the nation's farmland has been missing from agricultural policy debates. Manufacturing the products most Americans demand also generates residual material, which is mostly treated as wastes. While some are recycled, many of these wastes directly or indirectly find their way to surface and groundwater. Even the most seemingly innocuous of habits—for example, fertilizing our lawns to make them green in summer—can add potentially harmful nutrients to nearby waterbodies as excess nitrogen and phosphorus compounds wash off the land or infiltrate to groundwater when it rains. Every day the American public, including individuals and leaders of business and government, makes choices in arenas that appear unrelated to water quality, but do, in fact, affect it. There are six key areas of concern: o How we live; o How we produce and consume; o How we farm; o How we transport people and goods; o How we plan; and o How we have acted in the past. Currently, national water quality policies and programs do not address these societal origins of impairment. September 1990 Page 20 ------- How We Live The way Americans live is shaped by a variety of social and economic forces—the availability of inexpensive automobiles and gasoline as well as a lack of alternative forms of transportation, proximity of homes to centers of commerce and culture, and government incentives for home ownership, for example. The resulting land use pattern is a product of consumer preferences, local government decisionmakers, and land developers. Until recently, concern for environmental quality has not affected our way of life to any significant extent. But as lifestyles evolved toward decentralized urban and suburban centers after World War II, conflicts began to emerge between lifestyles and the quality of the environment. Environmental controls in general and efforts to improve water quality in particular increased in the 1950s and 1960s, frequently in reaction to crises. However, efforts to target and control urban and suburban growth and to plan for sound land uses have not always been sufficient. Sprawling growth continues to claim our open space, agricultural, and natural lands. By 1970, the conflicts between American lifestyles and water quality captured national attention. Twenty years later, we can point to much progress. However, we can also identify continuing water quality problems associated with how we live, such as runoff from roads and construction sites, contamination of groundwater from poorly designed or malfunctioning septic systems, discharge of untreated sewage from combined sewers when it rains, loss of open space with the development of new suburbs and degraded or destroyed aquatic habitat from overuse, unregulated recreational activity, or housing construction. Our challenge is to anticipate how lifestyle choices may affect water resources and then plan to live compatibly with preserving and improving water quality. The way Americans use energy also has significant implications for water quality, although the linkages are rarely spelled out. Modern life entails higher energy use than lifestyles of a century ago. However, Americans use energy half as efficiently per unit of economic output as do populations in other developed economies. More efficient use of energy in homes and cars—shifts that are well within the reach of current technology with net savings compared to current use—could reduce significantly the demand for oil, gas, and electricity. In turn, worldwide oil and gas extraction, processing, and transport could be reduced, with accompanying worldwide reductions in water pollution from these activities. Reducing worldwide oil and gas demand would also have September 1990 Page 21 ------- other benefits, including reduced downstream water quality impacts and production of acid rain, which results primarily from the combustion of fossil fuels. How We Produce and Consume Manufacturing processes that transform raw feedstocks into fundamentally different products must of necessity generate some residual materials. Until recently, industry practices and government regulations have thought of these materials almost exclusively as wastes, so they have been disposed of, with or without prior treatment, in the nation's rivers, streams, and lakes. This strategy has been costly both to society directly and indirectly, through decreased environmental quality. The U.S. market-based economy is characterized by private production and consumption decisions that are generally driven by concern for short-term profits and convenience. That is, producers make decisions as to whether and how to produce goods and services based on demand and their expectations regarding revenues from the sale of goods versus the cost of producing them. Many environmental problems originate in the difference between the private costs considered in production decisions and the external costs of those actions to society. Such societal costs include reduced recreation opportunities or increased incidence of disease from drinking contaminated water. While producers do not pollute out of malice, they may not take into account the environmental ramifications and or the costs their actions impose on society unless there are government regulations. Electroplaters, for example, would control the release of spent plating baths only to the extent that it is economically attractive to do so. Their calculation of what is or is not economic must compare the cost of purchasing new plating solution to the cost of buying and operating equipment to purify spent solutions. In the absence of regulations preventing discharge, whatever is not recycled would be discharged to sewers or to nearby waterbodies, possibly without adequate treatment. Because electroplaters would not have to pay directly for costs associated with the effects of the discharge, they would have no incentive to consider these "external" costs in the management decision of whether to recycle or discharge spent plating bath. Nonetheless, those uncontrolled discharges can reduce or eliminate fish populations, impair recreation, and impose substantial costs to September 1990 Page 22 ------- nearby drinking water supplies for removing harmful chemicals. Other environmental amenities, such as the overall health of aquatic ecosystems or the aesthetic value of clean water, cannot be fully measured in economic terms, but have value nevertheless. Without government regulations mandating such actions, industry has little incentive to shoulder the cost burden of pollution control when the benefits of clean water accrue not to industry specifically, but to all who use receiving waters for swimming, fishing, or boating. In a competitive market, producers who raise their own production costs by making greater investments in controlling pollution relative to other producers are likely to be driven out of the market. Well-designed government regulations can reduce the effects of these perverse incentives. Consumption patterns also are responsible for much of production waste. American consumers typically demand, or have been conditioned to expect, well-packaged products. And while packaging is often associated with product safety, hygiene, or longevity, by-products of our relatively inefficient patterns of consumption are too frequently disposed of with little thought to the consequences. Even though consumers have always had opportunities to exert such leverage through their buying power, only recently have they begun to influence production decisions by demanding environmentally compatible products, less packaging, or packaging materials with benign effects on the environment. For many types of products, we have grown used to the convenience of disposal rather than reuse. It is not surprising then that the United States produces more waste per person than any other industrialized nation. In fact, Americans often throw away what amounts to valuable recyclable resources in some other economies—used plastic bags—for example. There are indications that the way we produce and consume is beginning to change. In response to incentives beyond regulations —liability, public image, expanded markets for by-products, shifting consumer demands, widely available information, and new technologies, to name only a few—some industries are becoming more environmentally conscious, recycling materials and preventing pollutants at the source. Overall, however, society has not done an adequate job of sending consumer signals and developing, encouraging, and regulating private industry to make profits in ways that are consistent with protecting the environment. September 1990 Page 23 ------- How We Farm The production of food and fiber of necessity involves the disturbance of soil and water. Since a great deal of the American landscape is farmland, activities such as tilling the soil, applying fertilizers and pesticides, and irrigating fields make agriculture the largest source of polluted runoff in the country. Agricultural sediments, nutrients, pesticides, and salts can impair rivers, lakes, and wetlands; agricultural pesticides and fertilizers can contaminate groundwater; and agricultural development can displace natural wetlands. Many farms are characterized by monoculture, or the production of just one crop. Monoculture requires greater use of chemical fertilizers and pesticides than does diversified production. It also may cause more soil erosion. With few positive incentives, but facing significant impediments to change, the farm sector has been slow to adopt changes that can be equally productive and minimize environmental impacts through crop rotation, integrated pest management, soil and water conservation, and use of buffer strips to protect aquatic ecosystems. Improper irrigation practices result in leaching or drainage of excessive amounts of salts, nutrients, and pesticides from soil to surface waters, and infiltration of these constituents to underlying aquifers. Some government programs provide incentives to farm in ways that directly influence water quality and use. For example, federally subsidized irrigation water has been identified as a disincentive to conservation efforts. In addition, agricultural price and income supports encourage farming practices that lead to water quality problems. These practices may result in agricultural production on environmentally sensitive lands. In the West, water rights based on the "use or lose" principle (actual or perceived) also encourage excessive application of irrigation water. Policy decisions that limit consumer choices are also partly responsible for current farm practices that impair water quality. Grading standards and marketing orders administered by government and industry, for example, place a premium on unblemished fruit and vegetable products, which leads to greater use of pesticides and waste of nutritionally acceptable food. Consumers have come to expect year-round availability of such products. In addition, food packaging and value-added processing can contribute to water quality problems through the use of paper and plastics and the production and disposal of chemicals. September 1990 Page 24 ------- Timber harvesting, grazing, and concentrated livestock operations also contribute to water resource impairment. Grazing, timber, and mining subsidies often exacerbate impairment. Although environmental impacts of livestock and use of pasture and rangeland can be mitigated through proper management, degradation of adjacent rivers, streams, and lakes has been and continues to be a problem when grazing is mismanaged. The most prevalent problem is overgrazing, which causes erosion and loss of nutrients from the soil into waterbodies. In addition, when animals are allowed to graze riparian areas, they can seriously damage or destroy stream banks and vegetation as well as produce wastes that directly contribute bacteria and nutrients to water. Finally, water projects (ditching, channelization, dams) alter aquatic habitats and decrease biotic integrity (for example, extinctions and extirpations). How We Transport People and Goods Transportation is a vital force in the nation's economy. Although water quality implications rarely play more than a peripheral role when transportation decisions are made, transport facilities (roads, highways, railways, harbors) and vehicles clearly affect water quality in five ways: o Directly through disturbance or elimination of aquatic habitat; o Directly through runoff from surfaces, carrying contaminants such as deicing salt, oil drippings, brake lining dust, or fuel spills. o Directly by runoff to surface water and infiltration to groundwater from accidental spills of oil and other contaminants from trucks, ships, pipelines, and trains; o Directly from deposits of airborne contaminants released through the routine use of facilities and vehicles; and o Indirectly by helping to determine where we live and work; in particular by encouraging dispersed development patterns without adequate concern for water quality. September 1990 Page 25 ------- There is little controversy about the need to control these direct impacts, especially from land-based transportation. But marine transportation also contributes to water quality degradation in ways that are both anticipated and unanticipated. While national programs seek to minimize adverse effects, dredging ship channels to assure navigation eliminates habitat diversity and species and can resuspend toxic chemicals and other pollutants that had accumulated in bottom sediment. In addition, dredged material can present a problem unless disposed of in a proper manner and location. Improper placement of this material can destroy aquatic habitat; but proper disposal of uncontaminated material can be used for beneficial purposes, including beach nourishment, wave attenuation, wetlands creation or restoration, shallow-water habitat development, or uplands construction. Contaminated dredged material can cause numerous problems unless isolated from the water column by management techniques, such as confined disposal facilities, underwater capped mounds, or capped underwater depressions, that are suitably designed, sited, and operated. However, while most public attention focuses on direct effects, the indirect influence of transportation on land use and lifestyles could have a more profound impact on water quality in the long run. In recent decades, the U.S., along with other advanced economies, has increased its reliance on cars and trucks instead of mass transit and rail. While cars offer convenience in moving people and trucks offer efficiency in moving goods, highways are well-documented sources of contaminated runoff and their construction has sometimes destroyed wetlands and other aquatic habitat. Urban highways and other commuter roads have had the most far-reaching effect on water quality by facilitating and encouraging the nation's move to the suburbs, in 1980, nearly 60 percent of our urban population lived in the suburbs; almost three-fourths of the growth in the 1980s occurred in suburban areas.34 These trends show no sign of slowing, with 85 percent of the growth to the year 2000 projected to occur in the 50 largest metropolitan areas. In the past, we have failed to recognize the full environmental cost of development in land use and transportation policies. Our future challenge is to meet the transportation needs of the nation in ways that are compatible with good water quality. September 1990 Page 26 ------- How We Plan Resource and land use planning is essential to achieve economic growth that is compatible with good water quality. Yet, traditional planning efforts have not taken a broad enough perspective to anticipate effects on water quality or aquatic habitat over long enough periods of. time or over wide enough geographic areas. In some cases, when planners have failed to communicate clearly with those responsible for implementation, the resulting actions have been unrelated to even the best of plans. In other cases, despite adequate efforts to communicate, the location of development or transportation corridors has occurred more as function of local political pressure or the cost of land than of overall planning. Even when planners work well with politicians and the private development community, attention to water quality concerns may be inadequate because none of the participants are sufficiently trained in environmental disciplines. Traditionally, the need to provide a growing population with water and sewer services has driven planning related to water resources and pollution control. In the 1970s and 1980s, government increasingly regulated point sources and much water quality improvement resulted. However, these regulations usually followed the boundaries of political jurisdictions (states, counties, or municipalities) rather than ecological areas, such as river or lake drainage basins. In addition, traditional planning efforts focused on short-term delivery of services; they placed relatively little emphasis on long-range, strategic planning. Moreover, rarely has water planning incorporated interactions between water quantity and quality. Such needs are especially critical for planning adequate quantities of safe drinking water from all sources including surface water and groundwater as well as wastewater effluent and other nontraditional sources. The result of this legacy is that layers of federal, state, regional, and local government responsibility create a fragmented approach to planning. An emphasis on single-focus compliance ignores the importance of management on a broader geographic scale and over longer periods of time. The current paucity of consistently gathered data on the quality of the nation's waters, discussed earlier, is testimony to this relatively narrow, short-term planning perspective. Too often, point source data and chemical-specific permits dominate the process used to make decisions that affect entire watersheds. Data on runoff and ambient conditions (including September 1990 Page 27 ------- integrative biological evaluations) are not given equal status. For example, the majority of controls in point source discharge permits are based on achieving a certain concentration in the water at a specific site instead of by determining a total pollutant loading analysis for the watershed as a whole. Moreover, local ambient water quality is generally measured by concentrations of key constituents in the water column, only—not in the bottom sediment, in fish, or in other aquatic species. Further, little effort is made to assess the structural and functional integrity of biological systems within the water resource. Finally, rarely are the effects of upstream land use decisions or the cumulative impacts of many small human actions translated into basinwide changes in the quality of the water resource. The absence of a comprehensive planning strategy that is accepted and fostered by government and academic institutions has hampered our ability to properly use water resources and protect water quality. There have been some attempts to coordinate planning efforts for entire watersheds, such as EPA's areawide water quality planning program in the 1970s or, more recently, its National Estuary Program. However, such efforts remain more the exception than the rule. Even the most comprehensive of planning exercises often fail to account for cumulative effects. Local land use controls that account for water quality have also been the exception, although this may be changing. At the local level, most land planning has responded to growth, rather than guiding development in ways compatible with protection of recharge areas, conservation of aquatic habitats, or improvement in the quality of surface waters. The impact of sprawling development on watersheds, and consequently on water quality, has not always been recognized. Even if recognized, efforts to target and control growth have often been insufficient. Much more remains to be done to improve both the way we plan for general economic expansion and for the protection of water resources. We must consistently monitor changes in water quality and their effects on aquatic life to identify the most serious causes of impairment and, in turn, use funding efficiently. How We Have Acted In the Past Changes in how we live in the future will not prevent or remedy all damage to water quality. Water quality will continue to September 1990 Page 28 ------- be degraded by past uses of the land that contribute to continuing pollutant loadings and to physical damage to aquatic systems. Examples of these past activities with continuing impacts include drainage and leaching of pollutants from abandoned mines, tailings piles, solid waste and hazardous waste disposal areas, spills, pollutants in the bottom sediments, and pesticides and other materials currently present in the soil and groundwater systems. Past physical alterations, such as channelization, and continuing physical impacts of past activities, such as stream scouring and erosion, will also affect future water quality regardless of our changes in current practices. Introduction of exotic species have also occurred as a result of past activities. CONCUJSION The causes of water quality degradation are far from straightforward or simple. They are intertwined with aspects of life that seem far removed from concerns over water quality. In addition, traditional planning efforts have been too limited to achieve economic growth compatible with good water quality. The section that follows identifies the many impediments to solving these problems. September 1990 Page 29 ------- III. IMPEDIMENTS TO IMPROVING WATER QUALITY What are the major obstacles to improving water quality? The reports of the Water Quality 2000 work groups discussed a broad range of impediments emanating from a great variety of sources. Most of the issues raised by the work group reports can be summarized in terms of seven crosscutting types of impediments to improved water quality: o Narrowly focused water policy; o Institutional conflicts; o Legislative and regulatory overlaps, conflicts, and gaps; o Insufficient funding and incentives for water quality improvement; o Inadequate attention to the need for trained personnel; o Limitations on research and development; and o Inadequate public commitment to water resource quality. Effectively removing these seven impediments will result in near-term improvement in the nation's water quality. Work group members would agree that these seven issues are not necessarily equal in importance. Establishing priorities among them, however, is reserved for Phase III of the project, as explained earlier. Despite gaps in data, limits to scientific knowledge, and a need for new technologies, many believe that water quality improvements are attainable now. NARROWLY FOCUSED WATER POLICY Water quality programs in the 1970s and 1980s have emerged from relatively prescriptive, fragmented, and sometimes inflexible federal and state mandates. In part because they were easier to implement and installation was easier to confirm, water quality control strategies of the 1970s and 1980s relied on engineering solutions; little use was made of ecological knowledge and economic tools and other strategies capable of directing resources to September 1990 Page 30 ------- protect water resource quality. The easy targets--point source controls and conventional pollutants—were addressed first, largely outside of any comprehensive framework for overall water quality improvement. Consequently, too little attention was paid to measuring improvement in waterbodies as a whole. Instead, the measures of improvement corresponded to the fragmented policies— numbers of treatment facilities put in place or the reduction in frequency of discharge violations from individual point sources, for example. The result is the distinct lack of a holistic approach to water resource protection programs today. In particular, traditional fragmented approaches typically fail to address: o Watershed-based planning; o Cross-media effects (pollutants that cross traditional categories); o The relationship between water quantity and water quality; o Pollution prevention; and o Environmental results. Watershed-based Planning In Section 208 of the 1972 amendments to the Clean Water Act, Congress designed a framework to coordinate water quality programs. Section 208 directed basinwide and areawide planning to account for and set priorities over controlling municipal point sources, industrial point sources, and runoff from rural and urban lands. Over time, however, the 208 program produced many planning documents but largely failed to coordinate government programs or set priorities for investments in water quality. In part this was due to unfortunate timing—federal grants to build wastewater treatment plants began before the planning could help set priorities for funding. Much of the problem of policy fragmentation seems linked to our failure to recognize or reluctance to adopt the appropriate spatial scale, including patterns of water movement and biogeographic considerations, for water resource planning and management. This approach provides the framework to evaluate a September 1990 Page 31 ------- natural resource problem using a natural systems approach. It is well suited to track holistic cause-and-effect water quality relationships since it can link upstream uses with downstream effects. Without understanding these relationships, it is difficult to assess current or potential conditions or to remediate cumulative environmental degradation. Even where there is a watershed approach, ecological differences in the landscape between upstream and downstream areas often are ignored. Cross-Media Effects Many environmental professionals have recently come to recognize that many pollution problems do not fit neatly into the traditional typology of single-medium environmental laws and policies. A single disposal effort may potentially affect both water and air quality. Sludge handling under the Clean Water Act, for example, can have profound effects on groundwater quality. Nitrogen oxides released into the air, even in compliance with the Clean Air Act, can be deposited in waterbodies downwind, with significant degradation of water quality. Pollutants in surface and ground waters increase the cost of delivering pure drinking water. Following traditional, single-medium approaches, residuals can potentially be transferred from one medium to another. Under the Clean Water Act, for example, EPA established technology-based effluent limitation guidelines and standards for the organic chemicals industry that allow the use of air stripping. Under these guidelines, the water quality problem would appear to be eliminated, but air stripping can result in air pollution problems. Air regulators are then left to regulate emissions from wastewater treatment plants under the Clean Air Act. Alternatively, if industry uses steam stripping, the sludges produced may become a regulatory target under the Resource Conservation and Recovery Act. Shifting the management burden from one medium to another is inefficient from both public and private perspectives. In addition, transfers leave open opportunities for pollution problems to escape regulation entirely. In a striking example, Philadelphia recently attempted to control emissions within its airshed by requiring installation of precipitators on urban smokestacks. The solids and sludges that were removed, however, found their way to the Delaware River, either directly through discharge or indirectly through runoff from land disposal. Once in the river, metals and other September 1990 Page 32 ------- constituents that had been removed from smokestacks through air pollution controls were pushed upriver by natural tidal action until they entered the city's drinking water intake. Extra funds had to be allocated to remove these pollutants from drinking water supplies. The Relationship Between Water Quantity and Water Quality Water quantity is important to water quality in many areas of the U.S., yet the quantity aspects of water resources are almost always regulated and managed separately from the quality aspects. Water withdrawal for all types of consumptive uses can have profound effects on aquatic habitat downstream. To the degree that water is withdrawn from streams and not returned, less in-stream flow is available for fish and wildlife habitat, inputs to wetlands and other aquatic resources, and mixing in estuaries to preserve critical freshwater/saltwater balances and prevent saltwater intrusion into coastal aquifers. Water used, degraded, and returned to waterbodies can have equally significant effects on water quality. Irrigation return flows often have high concentrations of salts and metals, for example. In addition, excess water use places a burden on overloaded sewage treatment plants. Concerns for water quality also limit water use. Regulations that prevent estuarine salinity from exceeding acceptable levels for drinking water supplies can limit power plant withdrawals, especially during a drought. They also can affect the operation of upstream reservoirs. In a few cases, strict application of effluent discharge rules at wastewater treatment plants can alter water supply and in-stream flow when treated effluent constitutes a large part of the flow in the receiving stream. When water quality is impaired by point sources or contaminated runoff, the effective water supply available for human and environmental uses declines or the cost of water treatment (for supply) increases. Contamination of aquifers likewise eliminates or increases the cost of using groundwater sources for many uses. Pollutant Prevention Until very recently, the Congress and EPA have largely focused their efforts on treating pollutants once they have been generated, rather than preventing or reducing their generation in the first September 1990 Page 33 ------- place. The end-of-pipe treatment focus of the Act and other statutes fails to encourage or reward reduction at the source. The very focus on effluents in the Clean Water Act is testimony to the fact that legislators have not really begun to address ways to reduce waste at the source. Further, it reflects the dominance of a chemical perspective and a narrow concept of pollution (chemicals and other contaminants) that diverts attention from the biological and physical impairment that results from a wide variety of human activities. Moreover, setting uniform national technology-based standards may not require but tends to encourage installation of end-of-pipe technologies used to set discharge limitations. Such standards act as a disincentive for potentially more efficient local solutions to meeting performance targets, some of which could involve pollutant prevention. Even where the language of the law may authorize relatively more attention to preventing the generation of pollutants, legislative and regulatory policies have emphasized the granting of permits to discharge a limited amount of pollutants or cleaning up existing problems rather than eliminating or preventing new ones. The Clean Water Act, for example, established a goal of zero discharge. It explicitly calls for a standard permitting no discharge of pollutants, wherever practicable, but this provision of the act has not been widely implemented. While the Clean Water Act established this goal, it also created a permitting system that allows discharge of pollutants up to certain limits. Most states have relied on best professional judgment in setting these limits. States have only recently begun to adopt water quality standards based on specific quantitative criteria for metals and organic compounds or to include these limits in discharge permits. As a result, dischargers have had little incentive to reduce their discharges of these constituents below levels required by effluent limitations. Pollutant prevention strategies hold particular promise for addressing water quality problems caused by agricultural or urban runoff. While historical efforts to address soil erosion problems are analogous to practices to prevent the generation of pollutants, only recently have efforts been initiated to address agricultural water quality problems resulting from application of nutrients and pesticides. Similarly, controlling or preventing the discharge of pollutants from stormwater has only recently begun to be addressed. September 1990 Page 34 ------- Environmental Results Measuring the outcome of our water quality control strategies has proven elusive, in part because of the limitations of the data currently collected. At best, we have devised ways to count inputs —the number of permits written, the number of enforcement proceedings, or the dollars and staff devoted to a given problem. But in most cases, we have not chosen to measure progress by measuring environmental results. Overall, monitoring programs have not been used extensively to measure the status of water resources or to identify the causes of declines in quality when they are detected. Further, monitoring has not been used to assess the extent to which regulatory and other efforts have had the desired effect in improving the quality of water resources. Clean water programs have been less effective than they could be because of a failure to collect baseline data and statistics related to environmental results over time. This lack of data contributes to a lack of program accountability, inadequate or uncontrolled program oversight and implementation, uncertain direction, and the inability to focus limited resources on the most environmentally effective initiatives. While the Clean Water Act required collection and reporting of data on the attainment of its f ishable-swimmable goal, EPA has developed inappropriate or unclear accountability measures that are more related to administrative activities than to clear-cut environmental results. In its clean water agreements with states, in effect, EPA often ends up holding states accountable for collecting statistics on administrative activities rather than for achieving measurable environmental improvements. Historically, monitoring has focused on water chemistry, largely ignoring physical habitat, flow, and biology. This has resulted in substantial losses of aquatic ecosystems. Both the extent and the biological integrity of the resource has suffered, despite general improvement in water quality. Even where environmental data are used to assess results of programs, sometimes different EPA program offices collect noncomparable data or use incompatible systems or formats. A similar problem exists among the various agencies charged with protecting water quality (the Environmental Protection Agency, the National Oceanic and Atmospheric Administration, and the U.S. Geological Survey, for example). In 1988, a U.S. General Accounting Office report recommended that EPA do more to "manage for environmental results.I|3S September 1990 Page 35 ------- Development of improved biological methods over the past decade has provided a mechanism for assessing environmental results. Ohio and Maine, for example, have adopted biological criteria to assess resource status and trends. INSTITUTIONAL CONFLICTS Under the American system of government, federal, state, and local units share responsibilities for different aspects of the same program or for different programs. Implementing environmental initiatives under this system inevitably involves private participation and the commitment of individual citizens or their representative groups. Relationships among these key players are largely constructive; opposing viewpoints can be voiced and compromises reached. Yet conflicts can arise over the allocation of authority and responsibility among government units, the private sector, and individual citizens. Two types of conflicts can cause serious impediments to improvements in the nation's water resources. First, conflicts can arise out of the balance of authority among the key players. Second, conflicts can arise among different participants within each level of authority. The following sections present the current role of the key institutional players in water quality and note the critical conflicts that often arise. Federal Government While the federal government participated in water quality control to some degree in the 1950s and 1960s, surface water quality was predominantly a state and local concern until 1972. In that year, the federal role in setting standards and charting a national program direction for surface waters began to grow. Throughout the late 1970s and 1980s, states began to adopt the role of implementing agents of the federal program but retained their authority to enact stricter or more expansive water quality controls so long as minimum federal requirements were met. While local governments continued their role as owners and operators of drinking water and wastewater treatment facilities, the pace of construction of wastewater facilities was greatly hastened under an expanded federal grants program. The 1974 Federal Safe Drinking Water Act focused local attention on the quality of drinking water. September 1990 Page 36 ------- Federal programs in water resources development and protection have undergone several major shifts since the late 1800sr when the Corps of Engineers was first authorized to protect the nation from floods. Today, more than a dozen federal agencies conduct programs in such diverse areas as navigation, flood control, irrigation, hydropower production, ecosystems preservation, fisheries and shellfisheries restoration and maintenance, coastal and marine protection, and basic water use and quality data collection and analysis. With so many federal agencies involved in water resources and water quality, it is not surprising that they sometimes overlap or conflict with each other. For example, federal land management agencies may work at odds with water quality goals when they seek to maximize timber production, mining output, or grazing acreage. One federal agency with authority for delivering irrigation water to off-stream farms may have little regard for another agency's goals for alternative in-stream water uses, such as maintenance of aquatic habitat. As already discussed, conflict is fundamental to the American form of government. Federal mandates that apply nationally may be inefficient when applied in some localized situations. Yet, a strong federal role is often needed to ensure some minimum level of environmental quality nationwide, despite the conflicts or inefficiencies that may arise. State Government States play a key role administering national clean water and drinking water programs. Historically, the federal government has supported this role with grants for state program operation. But the federal budget deficit, continued expectations for maintenance of base programs, plus new initiatives enacted by Congress, are expected to pose serious funding problems for state water administrators within the next several years. By the mid-1990s, for example, states could face an aggregate deficit of some $400 million a year between the cost of clean water and drinking water programs mandated by Congress and combined federal and state funds currently available to administer them.36 Moreover, the demand for resources to run state clean water programs will compete with equally large demands for funds to administer solid waste and air quality programs. September 1990 Page 37 ------- While the states are being asked to assume more leadership in water quality programs, clear accountability and responsibility for those programs has not yet registered at the state level. The responsibility for these programs has not been matched by the financial resources or political independence necessary to accomplish the job. In some instances, while states work to improve their programs, current controls are inadequate to ensure against degradation of water quality. On the other hand, in many respects states have not fully met their obligations under Clean Water Act programs. For example, state water quality standards have lagged behind federal guidance, leaving gaps and other problems in state water programs. In addition, state agencies may have inadequately coordinated policies and procedures, such as among agriculture, drinking water, transportation, health, and aquatic habitat protection. Where this occurs, some programs can lose effectiveness. Local Government Local governments are responsible for delivering clean water services, such as drinking water, wastewater treatment, and stormwater control. They also assist in implementation of national programs, including wellhead protection, the preservation of aquatic habitat, and industrial pretreatment. Wellhead protection relies on local data collection, land use ordinances, and zoning controls. Pretreatment of industrial discharges requires local implementation. Perhaps most important in terms of current water quality programs is the key role that local governments play in integrating land use management with water quality protection. But local land use decisions rarely are based on water quality factors, and water quality gains achieved by federal and state regulatory programs often are offset by development at the local level. In the case of drinking water, the nation's most serious contamination problems are associated with the 13 million private wells and 180,000 small public water suppliers (serving fewer than 3,300 people each).37 Yet, even though a large number of small entities are recognized as the source of the problem, the role for local governments, which are closest to the problem, remains relatively restrained. This situation leads to an underuse of local land use controls (a traditional province of local government), public education, and technical assistance. September 1990 Page 38 ------- In the 1970s and 1980s, a doubling in the number of local water and sewer districts enabled financing of these services without restrictions imposed on municipalities. Yet special districts may not provide the best or most cost-effective services due to lack of economies of scale. Local attainment of Clean Water Act goals has been impeded, to a degree, by other government programs that may be based on sound policy reasoning but that have an unintentionally perverse impact on water quality. Over the past eight years, for example, the U.S. Tax Code has been revised six times to reduce tax abuses and promote tax equity. While changes have appropriately supported these goals, each revision has further curtailed state and local ability to meet water infrastructure needs through the issuance of tax-exempt bonds and reduced incentives for the private sector to finance such needs. Limits on tax-exempt bonds to finance public-purpose, government-owned water and sewer projects plus other restrictions on tax-exempt financing have increased significantly the cost of building these facilities.38 The Private Sector The private sector has a pivotal role in (1) complying with controls for the 126 priority pollutants and other contaminants; (2) preventing pollution; (3) implementing nonpoint source controls; (4) financing and/or operating assistance for water and wastewater infrastructure; (5) creating new products (and markets for products) in response to consumer demand; and (6) educating consumers on how to use products without impairing water quality. The private role in controlling the release of heavy metals and organic compounds is self-evident. Some drinking water sources drawn from both ground and surface waters have been contaminated with industrial toxic wastes, representing significant economic, aesthetic, and human health losses. Reproduction of aquatic species has also suffered, as a result—at least in part—of exposure to industrial toxins, with the nation's attention now turning to the environment, the private sector faces increased pressure to do more to reduce or otherwise control toxic releases into air, water, and the land. Less widely recognized but probably equally important is the private role in controlling runoff. The essential character of runoff problems is the ubiquity of sources, many of them private. Agricultural pollution stems from uncountable day-to-day activities September 1990 Page 39 ------- and management decisions taken by farmers as they interact with highly site-specific conditions (soil type, field slope) and natural events (rainfall, temperature). The millions of private entities and uncontrollable natural events involved greatly complicate the abatement of runoff. Another critical but largely unassumed private role is to provide the farm sector with new, environmentally conscious instructions on the use of fertilizers and pesticides. A behind-the-scenes but nonetheless important activity is the private sector's participation in financing or operating the environmental infrastructure. While estimates vary on the exact sums involved, almost all analysts concur that future needs to build and operate water and wastewater facilities outstrip current public resources devoted to these purposes. Historically, government fiscal, tax, and environmental policies and programs have tended to discourage private participation in facility construction, ownership, operation, or management and in assistance in program administration. Some view the private sector as a great untapped resource in these areas. Manufacturers have already begun to take on a role as proponents of "green" products—products that require less environmentally harmful inputs for production, produce few residuals, and are believed to be more compatible with the environment during their useful lives and after disposal. In response to a growing demand for such products and increasing sensitivity to liability associated with waste disposal, some producers are beginning to promote "green" products in place of environmentally harmful ones, at least in a limited way. Citizens• Organizations Citizens, both as individuals and through citizens' organizations, have a central role to play in protecting water resources. In decisions about facility siting, land use management and zoning, transportation, permitting, and protecting natural resources, the viewpoint of affected communities is critical. LEGISLATIVE AND REGULATORY OVERLAPS, CONFLICTS, AND GAPS While eliminating these concerns entirely would be an unrealistic goal, a principal impediment to forming solutions to September 1990 Page 40 ------- today's water quality problems are the many instances of legislative and regulatory overlaps, conflicts, and gaps. o Overlapping statutory or regulatory controls as well as other policies and programs are inefficient unless they are carefully coordinated and work toward the same goal. o Conflicting legislative authorities, policies, and programs are potentially counter-productive. o Gaps in authority, policies, and programs underprotect water quality and water-based natural resources. The evolution of water quality laws from the 1960s to the present reflects several trends: increasing federal responsibility, enactment of new authority to fill gaps, increasingly explicit requirements for treatment of toxic levels of metals and organic compounds, increased attention to biology, and longer and more-detailed statutes. As information available to policymakers improved, laws and policies shifted from abating acute hazards to preventing chronic low-level hazards. Instead of focusing on a few pollutants, regulators began to address hundreds of substances of potential concern. The earlier focus on single-medium pollution problems has begun to shift to include inter-media pollutants that cycle from air, to land, to water. Similarly, single-chemical criteria are being supplemented by whole effluent and ambient toxicity, as well as ambient biological and physical habitat criteria. It is not surprising that a patchwork of sometimes overlapping and conflicting legislation has resulted. These inconsistencies have serious effects. They often send mixed messages about which environmental values are to be protected and how much protection will be provided. For example, similar processes may be required to meet different and inconsistent standards under different statutes with the common goal of protecting groundwater. Overlapping Statutory or Regulatory Controls Overlapping statutes or regulations can impose unnecessary costs on both the public and private sectors—sometimes with no net gain in environmental benefits. At least four federal statutes, for example, require some monitoring and reporting on groundwater September 1990 Page 41 ------- quality. Fragmented and inconsistent reporting requirements reduce the overall efficiency and effectiveness of groundwater protection efforts and may impose unnecessary costs. Commercial or industrial facilities are sometimes required to report the same data to, or obtain overlapping permits from, several different EPA offices as well as other federal, state, or local agencies. The state of Louisiana, for example, requires that all dischargers to surface waters obtain a permit to do so from the state. But the state does not operate a federally approved discharge permit (NPDES) program, so all dischargers have to obtain an additional NPDES permit from the EPA for the same discharges. Currently, Louisiana's industries and municipalities pay permit fees under the state program, and they could become subject to pay federal fees as well, if EPA institutes an NPDES fee program as proposed in the administration's Fiscal Year 1991 Budget. Some states are also proposing fees for ambient monitoring programs. Too many regulatory institutions may leave no single agency really in charge. Many agencies representing different political and programmatic jurisdictions are tasked with agricultural pollution control, which creates difficult planning and communication problems. Even when interagency planning does occur, as was the case in Section 208 of the Clean Water Act or as is now the case under Section 319, problems arise. Because typically one set of agencies does the planning while another set does the implementing, program efforts often diverge from the planning blueprints. Conflicting Policies and Programs Today's patchwork of laws and rules create the potential for water quality policies to conflict with policies in other arenas. By providing tax deductibility for second home mortgages, for example, the federal tax code promotes the construction of second homes, many of which are located in environmentally sensitive or heavily stressed areas along the coasts or adjacent to mountain wilderness lands and headwaters. Farm policy still works at odds with water quality policies despite the changes in the 1985 Farm Bill. Federal commodity programs raise prices above market levels, which encourages farmers to intensify their use of program cropland through additional cultivation, added agrichemicals, and greater irrigation. All these factors may increase the discharge of nonpoint source pollutants, September 1990 Page 42 ------- habitat destruction, and extirpation of species. The design of current commodity programs also constrains farmers from choosing the mix of crops and type of management that would be most environmentally sound. Base acreage rules limit farmers' flexibility to rotate crops or to plant non-program commodities, even though these activities might reduce adverse water quality impacts. In addition, our national policy of dredging to drain lands and maintain shipping channels along navigable rivers and building dams for navigation, water supply, and electric power are at odds with both water quality and aquatic ecosystem conservation policies. Careful planning can mitigate but not eliminate these adverse effects. Without such precautions, resuspension of contaminated sediments can pollute surface waters. Improper placement of such dredged materials in certain land locations can also contaminate underlying groundwater. Dams, reservoirs, and dredging, including inappropriate placement of any type of dredged material, can eliminate sensitive aquatic habitats, remove fish habitat, destroy bottom-dwelling communities in both freshwater and marine environments, and prevent or hinder fish migration. Gaps in Authority With the vast array of federal, state, and local water quality statutes and programs described in this report, it may seem surprising that gaps still remain in our regulatory structure. However, such gaps do exist. For example, while the Clean Water Act, Superfund, RCRA, and FIFRA each address distinct aspects of groundwater protection, none is designed for total resource protection. A comprehensive legislative mandate to protect groundwater does not exist. Instead, laws intended to protect drinking water supplies, control specific contaminants and sources, or clean up aquifers provide a patchwork of groundwater protection activities. Protection has been incomplete in some areas, such as individual drinking water wells (which are exempt from federal legislation) and inconsistent in others. Also no statute provides for nationally consistent accounts to be kept on the current condition of groundwater or to relate ground and surface (fresh and marine) waters as an integrated system. Current water quality criteria often do not afford adequate protection to human health and aquatic life. Similarly, criteria are not always developed for both fresh and marine waters. More September 1990 Page 43 ------- effective application of available knowledge would result in better protection. However, establishing the comprehensive chemical, physical, and/or biological criteria essential to protecting aquatic ecosystems is difficult. Gaps in treatment of some water problems are attributable to both the absence of legislative attention and to unsatisfactory implementation of existing authorities. For example, even though they have been authorized by the Clean Water Act, the following criteria have yet to be published by EPA: o Numeric water quality criteria for the full range of pollutants (not just priority pollutants) for all uses and types of aquatic systems, including human health, aquatic life in rivers, lakes, estuaries, and marine waters; o Criteria for whole effluent toxicity and total human toxicity; o Sediment criteria; o Criteria for residues of toxics in fish and shellfish that address toxicity to these species and to humans who consume them; o Criteria for wildlife that use aquatic systems and biocriteria for overall health of aquatic systems, including wetlands, estuaries, freshwater systems, and marine waters; and o Groundwater criteria, apart from public drinking water standards. In addition, effluent guidelines and standards authorized by the Clean Water Act are not complete. According to EPA, four out of five direct industrial discharges are not covered by current guidelines specific to their industrial category.39 Substantive stormwater regulations and technology-based regulations for combined sewer overflows are also lacking. Regulatory programs for sewage sludge quality and runoff controls are still in development or only under consideration. September 1990 Page 44 ------- INSUFFICIENT FUNDING AND INCENTIVES FOR HATER QUALITY IMPROVEMENT At the same time that public opinion polls and political rhetoric suggest that our national commitment to clean water is strengthening, appropriations to administer clean water programs are reduced and capital facilities for water pollution control are under-funded. But the cost of water programs continues to escalate. According to the EPA, the cost of simply maintaining today's level of drinking water and water quality programs will increase from $31.3 billion a year in 1987 to $42.3 billion by the year 2000.40 Adding the new programs that are currently authorized but not yet in place will add another $4 billion a year by 2000. Devising efficient solutions to reduce the cost of clean water and healthy ecosystems, paying the remaining costs, and allocating funds among competing environmental investments are among today's most critical water quality issues for government and the private sector. Who pays and how much become even more critical in light of equal or greater demands on limited budgets placed by other environmental needs such as management of air quality or hazardous and solid waste. The federal government is clearly withdrawing from its historically prominent position as financier of water programs. In dollars of constant purchasing power, EPA's water quality budget in 1990 is one-third lower than its 1980 budget. EPA's 1990 support for building wastewater treatment facilities is almost half the 1980 level. This support will be eliminated entirely after 1994. One might argue that federal financial devolution is appropriate because the prominent federal role of the 1970s and 1980s is giving way to state and local dominance as the federal government increasingly delegates programs to the states. But this decline in purchasing power has occurred simultaneously with increased national water quality mandates and program responsibilities. Imbalances between mandates and funding could grow more serious as the federal deficit continues and as emerging areas of concern are addressed. These areas include aquatic habitat protection, nonpoint source control, groundwater protection, control of toxic pollutants, and stormwater/combined sewer overflow management. State water quality and drinking water budgets are also under strain, caused in large part by the withdrawal of federal grants and the new requirements for administering water quality and drinking water programs authorized in the late 1980s. Estimates of the gap between program needs and available funds by the mid-1990s September 1990 Page 45 ------- range between $250 million and $500 million a year. EPA's State Funding Study addressed this concern and concluded that increased funding at both the state and federal levels would be necessary to raise water programs to levels contemplated under current policies. Local governments are expected to feel the full effects of federal withdrawal as the transition from construction grants to State Revolving Loan Funds to build local wastewater treatment plants is completed in the mid-1990s. Even under full appropriations, which has not yet occurred since authorized levels were established in 1987, combined EPA assistance to build local treatment plants would fall at least $1 billion short in each of 17 states.41 To meet the discharge limitations established in the Clean Water Act, localities in these states will face unprecedented increases in local user fees and capital formation requirements. Limited financial resources also may limit protection of aquatic resources by all levels of government. Current methods to assess the economic value of water resource functions that emphasize production of commodities, for example, do not allow an aquatic ecosystem in its natural state to be favorably compared in terms of dollars to a project that would alter the system for direct human use. As a result, all types of programs to protect aquatic ecosystems may be underfunded. Advances in environmental economics and ethics are likely to alter societal views in these areas. Resources for runoff control programs also are limited. To date, spending on polluted runoff generally, and agricultural pollution specifically, has been dwarfed in comparison to spending on point sources. There may have been a time when this was justified, but as polluted runoff increases in relative significance nationwide, the justification is fading. Stated simply, the lack of funding for runoff control programs has become a fundamental impediment to accomplishing real gains in water quality. The private sector cost of clean water is substantial--just over $13 billion a year in 1989 for water quality and drinking water. As new regulations are phased in, costs are expected to increase substantially. A common assumption is that the private sector simply passes the cost of pollution control on to the consumer as increased prices for goods or services. But in a weak domestic economy or in the face of price competition on the international market, such price increases may be possible only at the expense of slower sales, reduced market share, cutbacks in the labor force, or some combination. Moreover, raising the funds to September 1990 Page 46 ------- invest in pollution control facilities may be difficult for some small or marginal businesses. Many economic incentives that could encourage public and private investment capital for funding improvements in drinking water supply and wastevater treatment are no longer available. This has significantly increased the cost of capital for these systems. Not only are pollution control funds limited, but so are funds to adequately monitor the environmental effects of control programs. State and federal monitoring is inadequate for unbiased estimates of waterbody quality, from which to better decide how to allocate limited control funds. Our ignorance of status and trends also prevents us from educating the public about related risks. INADEQUATE ATTENTION TO THE NEED FOR TRAINED PERSONNEL Clean water is a public good whose protection requires public control, which, in turn, requires adequate human resources assets to be effective. Assuring progress toward achieving national water quality goals will require a continued influx of sufficiently trained, adequately paid professionals. According to a recent review of the demand for engineers, for example, the American Society of Civil Engineers concluded that the need for environmental engineers will grow more rapidly than for any other engineering discipline through the turn of the century.42 Since 1980, the number of Americans employed in science and engineering has risen twice as fast as employment in general.43 Yet, in a number of industrialized nations, the percentage of total labor force trained in science and engineering is growing faster than in the U.S. In some water disciplines, the gap between supply of new professionals and demand for their skills is particularly wide. Demand for environmental engineers, for example, is greater than supply by a factor of two or three.44 Groundwater pollution specialists are in even shorter supply. Nearly 40 percent of the chemists and engineers constituting today's scientific work force will be eligible for retirement within the next five years.45 Professional education—both academic training and continuing education—must provide more opportunities to build the skills and experience needed for national clean water programs. After examining demographic data and historic trends, for example, one recent study concluded that a cumulative shortfall of several September 1990 Page 47 ------- hundred thousand scientists and engineers at the baccalaureate level might develop by 2000.** That shortfall could translate into an annual supply-demand gap of several thousand scientists and engineers at the Ph.D. level, with the shortage persisting well into the 21st century. Such a trend in science and engineering as a whole suggests that we examine salaries for positions in government clean water programs with an eye to how they meet the competition. At today's rates, government may be unable to attract and retain skilled employees. High turnover rates may result, as public employees leave government for better paying industry jobs. Strong leadership is needed from our academic institutions, the professional community, political institutions, and the media to turn around the recent decline in federally supported student stipends. The number of federally funded graduate stipends (fellowships, traineeships, and research assistantships) declined from 80,000 in 1969 to 49,000 in 1989.47 Declining levels of support, however, may be only part of the problem. Scientists and engineers apparently do not put much effort into communicating the values that make science attractive. With world-class research facilities on college campuses across America, why do few research professors pay attention to teacher training programs at their universities or, indeed, why do so few willingly sacrifice even a small percentage of their budget to improve such training programs? Current academic programs have limited access to the growing knowledge base that constitutes the foundation of clean water programs and do not integrate it well into the curriculum. Natural resource managers, lawyers, economists, and civil engineers need a skills base that goes beyond the traditional training of these disciplines. Natural resource management requires staff trained in biology, natural resources, water quality, environmental engineering, cost planning, recreation, urban development and land use, geographic analysis, sociology, and public relations. It is no longer sufficient to train one group of engineers to produce products and another group to clean up after them. And, considering the high visibility that most environmental issues receive in the eyes of the public, environmental leaders also must posses effective written and verbal communications skills and have a keen understanding of the impact of problems and solutions on society.48 But academic training by itself will not necessarily be sufficient to address tomorrow's water quality problems, such as controlling contaminated runoff. Failure of past control programs stem, in part, from lack of perspective on the real long-term goal of water resource protection and a failure to train professionals September 1990 Pa8e ** ------- to work with individual citizens. As the nation turns its attention to controlling contaminated runoff, planners will be needed to develop land use regulations that are sensitive to water quality issues. Too few agricultural specialists and farm advisors are now adequately trained in the effects of farming on water resources and in techniques to reduce these effects. In addition, these personnel may have inadequate training or resources to communicate water resource concerns to the broader public. Few programs are in place to educate consumers about safe use and disposal of agricultural chemicals, and there are too few efforts to train dealers, distributors, and farmers in the safe handling and efficient use of agricultural chemicals and fertilizers, manures, and other nutrients. Public policy managers must be trained to understand social values underlying societal origins of water quality problems and risk assessments to establish priorities. They must also be trained to evaluate the costs and benefits of alternative approaches to improve water quality and to assess regional aspects of water resources. Enforcement of regulatory programs requires standards that are ecologically sound and that will hold up under court challenges. Therefore, managers will need expertise to resolve legal difficulties related to scientific uncertainty behind control measures. LIMITATIONS ON RESEARCH AND DEVELOPMENT Although ecological knowledge relevant to the solution of water resource problems is often limited, careful application of existing knowledge by water resource professionals would improve the condition of those resources. At the same time, current research and development programs are not keeping pace with demands for scientific information. All too frequently, decisionmakers rely on best professional judgment instead of empirical information. A limited national research and development (R&D) effort is part of the problem. While in dollar terms the total U.S. effort is the largest in the world, Japan and Germany each invest more in R&D as a percentage of their gross national product (GNP) than we do, and other countries equal our current rate.49 EPA's Science Advisory Board reported that the Agency's 1991 budget request for its Office of Research and Development— barely sufficient to keep up with inflation compared to 1990 and lower in terms of constant purchasing power than in 1980—• is grossly September 1990 Page 49 ------- inadequate. The Science Advisory Board predicts the Agency will face difficulties attracting the kind of talent needed to replace an aging scientific work force.50 Policy decisions concerning dredging for navigation, as mentioned earlier, often suffer from a lack of sound economic evaluation methods and a limited understanding of the nature and magnitude of contaminated sediments. Managers cannot discern the best alternatives because there is insufficient research on the concentration and toxicity of contaminants in sediments and the bioavailability of potential contaminants to marine organisms. similarly, much remains unknown about health effects of treated waters or pesticide contamination of ground and surface waters. Insufficient data are available on long-term health effects of some pesticides, the risks of pesticide breakdown products, and the potential health effects of exposure to multiple pesticides, before decisions are made to register pesticides for use. Nor do we know enough about actual pesticide use patterns and the amounts of pesticide residues getting into surface and ground waters under these use patterns. We also lack detailed information—notably a reliable, comprehensive database on pesticide use—to enable full understanding of the amount of specific pollutants attributable to different sources in agricultural runoff. In addition, a greater understanding of soil-water-plant relationships is needed to develop improved management practices. Although some stream and lake restoration projects have been successful, current technological solutions simply are incapable of filling the gaps produced by ecosystem degradation. It remains unclear whether creation or restoration of wetlands are technically or scientifically feasible. Hence, restoration of many types of wetlands remains in the experimental stages. Technology development is needed for new cost-effective procedures and equipment to detect and remove contaminants in drinking water. Problems arise because regulations often are written ahead of needed research and technological development and, at the same time, federal R&D funding is limited. In addition, in the water supply industry few market incentives exist for private sector technology development. The nature and magnitude of atmospheric transport of pollutants is an area lacking sufficient research. For example, even as atmospheric deposition, runoff, and leaching of toxic metals into surface water and organic compounds into groundwater are widely recognized as areas of concern, most research programs fail to address them. September 1990 Page 50 ------- As well, complex water quality issues such as cross-media effects and the cumulative impacts of human activities on water quality receive too little attention. Finally, past government research and development policies have focused almost exclusively on end-of-pipe or other types of pollution controls. In comparison, preventing the generation of pollutants in the first place has earned too little government funding. The lack of scientific information is one of the principal impediments to making the transition from end-of-pipe controls to source reduction. Many who might otherwise choose to reduce the generation of waste or consumption of water simply lack information on the means to do so. That is, industries may be unfamiliar with the notion that improved process design and operation could help them use inputs more efficiently and generate less waste. One reason for this information lag is that our traditional regulatory programs have not yet elevated source reduction on a par with treatment technologies. INADEQUATE PUBLIC COMMITMENT TO WATER RESOURCE QUALITY We can point to some success in public commitment in the growing numbers of environmentally literate citizens who push the professional community, public agencies, and industry toward policies and programs for cleaner waters. On the other hand, a vast public also exists that is uneducated or misinformed about the relationship between clean water and a healthy economy. While it is popular to assume that a healthy economy cannot coexist with a healthy environment, it can and must. The environment and the economy are not necessarily at odds. The public generally receives effective communication concerning water quality crises. In contrast, when water professionals deliver satisfactory services, they receive little recognition. As infrastructure to the economy and community well-being, water and waste services remain in the background. The public should expect adequate quantities of safe drinking water and pollution-free streams. At the same time, water quality personnel do not do an adequate job of communicating the difficulties in achieving those goals. Partially because of our failure to communicate the relationship between human activities and degradation of water resources, the public does not feel responsible for its actions that affect water quality. Ordinary citizens remain largely unaware September 1990 Page 51 ------- of what they can do to improve water quality or to reduce use. Communicating to citizens and private industry that they must take greater responsibility for the wastes they produce directly and for the wastes produced as a result of their consumption of manufactured products has not been given enough priority. Industry and consumers have little understanding that wastes can be used as a resource without negatively affecting human health or the environment. Since traditional market mechanisms do not include the environmental cost of producing certain goods, alternative mechanisms are needed to tell citizens how their choices affect the environment. Not applying ecological knowledge, described earlier, hinders effective communication about water quality issues and best management practices to minimize adverse water quality impacts. Private commercial interests also sometimes tend to limit communications that would further environmental gains. Industrial and commercial competition nay preclude companies from sharing information about manufacturing processes that are environmentally protective. Consumers and producers are generally unaware of how their choices can affect water quality. Few consumers understand that their preference for unblemished fruit may lead to increased pesticide runoff and concentration in game fish and water supplies. The American public is also generally unaware of the true costs of ensuring a safe and uninterrupted supply of water for drinking. When systems are financed from general taxes, the true cost of drinking water is hidden from the consumers. Even when homes and industries are metered and charged according to use, many drinking water systems charge less than full cost of service, making up the difference with general revenues. As explained earlier, the perception that safe tap water is a cheap commodity may be on a collision course with budgetary and regulatory trends. Another reason for deficiencies in public understanding of aquatic resources is that education programs from kindergarten through college have failed to stress the value of these resources and the dependency of humans on a self-sustaining, healthy ecosystem. As a result, even educated people lack sufficient understanding of the nature of the environment, the environment's fragility, society's impact on the environment, and even more directly, the consequences of individual actions such as lawn care, home car-care, or disposal of household chemicals. One of the areas least understood by the public is the functional value of natural aquatic ecosystems. Few understand that these ecosystems provide September 1990 Page 52 ------- flood control, water quality enhancement, recreational opportunities, fish and wildlife habitat, groundwater recharge, shoreline protection, water storage, and natural green belts with aesthetic value. In many respects today, we lack a clearly articulated environmental ethic that would enable us to value natural ecosystems for their own sake. This is an impediment to resolving water resources problems because it makes it difficult to balance the values of natural systems against other societal priorities. CONCLUSION Water Quality 2000 has identified many impediments to solving our water quality problems. Many of these center on defects in the programs and policies currently in place. Others result from inadequate resources devoted to the problems—low levels of funding, inadequate application of existing knowledge, insufficient research and development efforts, and the potential for a personnel shortage. Nor does the public sufficiently understand factors that impair water quality or the growing threats to the availability of clean, abundant water. September 1990 Page S3 ------- IV. WATER QUALITY CHALLENGES FOR THE FUTURE As this report explains, the root causes of many water quality problems are the activities of our society. As we begin to address these root causes, it will be necessary to think carefully about the dual pursuit of water quality and societal goals. Disagreements will arise concerning the relative importance of water resource quality as compared with other social, environmental, and economic goals. Yet initiating the debate over compatibility of these goals is critical to improving the condition of the nation's waters and aquatic resources. Hater Quality 2000 has concluded that the results of public and private efforts to control sources of impairment and generally improve the quality of waters and aquatic ecosystems over the years have been mixed. Some problems have been solved, others await the results of programs only recently put in place, while still others remain challenges for the future. A major challenge facing water managers will be to convey to the public a clear picture of what constitutes our water resources and the real risks we face as a result of their degradation, their interconnectedness with other parts of the environment, and how natural and human activities may affect water quality. Recognizing a longer-term goal of moving the water quality debate toward the root causes of impairment, the pages that follow present Water Quality 2000's assessment of the key emerging near- term issues concerning water quality. PREVENTING POLLUTION Where there has been a sufficient economic incentive to do so, industry generally has improved the efficiency of manufacturing processes and hence prevented pollution. But only recently have government and industry turned their attention to preventing pollution in the name of environmental protection as an alternative to disposing waste once it has been generated. Heightened attention to pollution prevention is due, in part, to the increasing costs of pollution control attributable to traditional forms of regulation and, in part, to a more fundamental rethinking of the other economic advantages of pollution prevention. As a rule, those who promote pollution prevention advocate a hierarchy of alternatives whereby reducing the generation of waste would take precedence over recycling or reusing September 1990 Page 54 ------- waste once generated. In turn, recycling and reuse would take precedence over waste treatment. Only after these options are exhausted would the remaining residuals be disposed of as wastes. The impediments to implementing these principles include: o a lack of economic and/or regulatory incentives to change current waste management practices; o inability to access information on how to prevent pollution; o a lack of willingness to overcome the inertia from years of conducting business without explicit concern for pollution prevention; and o physical inability to add technology or make process changes that would result in less pollution. Our challenge is to better understand the impediments standing in the way of pollution prevention and to promote adoption of the hierarchy stated above in ways that are technologically acceptable and economically feasible. The pages that follow present Water Quality 2000's assessment of the key emerging issues concerning water quality. CONTROLLING RUNOFF FROM URBAN AND RURAL LANDS Largely because many of our past efforts have addressed point sources, controlling runoff from farms and urban centers in the future is likely to be far more important to improved water quality than, say, removing the final 5 to 10 percent of pollutants from domestic sewage. EPA studies have found that, since most of the conventional pollutants have been removed from domestic and industrial wastewaters, runoff from urban and rural lands is the predominant cause of water quality impairment in more than half the nation's rivers and streams. Controlling runoff poses significant challenges to conventional pollution control strategies, given the diversity of human activities on the land and the direct relationship between land use and the contamination of runoff. Agricultural runoff, which contains priority constituents and excess nutrients, is widely dispersed over the landscape. The practice of applying fertilizers and pesticides in amounts greater September 1990 Page 55 ------- than the ecosystem can assimilate is a basic impediment to control. Developing and implementing land use management measures that prevent or reduce impairment rather than mitigate it after it occurs is a major challenge. FOCUSING ON TOXIC CONSTITUENTS We face major technological and economic challenges in preventing the generation of toxic constituents in the first instance—both toxic wastes and products that may be toxic in their own right. In addition, we face challenges in improving current end-of-pipe control technologies. Tomorrow's water quality problems are more likely to center on toxics, including metals, organic compounds, and radioactive constituents than they are on conventional pollutants. While guidelines limiting concentrations of toxics in point sources were put in place between 1977 and 1989, control of toxic pollutants in discharges is only now gaining momentum. Many more toxic compounds found in waterbodies are released with no control at all. Water quality professionals are only just beginning to seriously consider how to deal with locally contaminated sediments and the buildup of toxic metals and other compounds from unchecked discharges and runoff of past decades. Moreover, a significant source of toxics in water is atmospheric deposition. Controlling these sources implies strengthened air toxics regulations. Compared to toxic releases to water, toxic discharges to air have been underregulated at the federal level and inconsistently regulated by individual states under federal and state authorities. Given recent advances in our ability to detect toxic metals and organic compounds in minute amounts, the policy challenge for future control of toxics is a better understanding of the risks to health and ecosystems of toxics in trace amounts. PROTECTING AQUATIC ECOSYSTEMS Many aquatic ecosystems have been degraded or destroyed by a broad range of human activities, including construction of residential subdivisions, new transportation systems, and recreational developments. These physical losses result in fewer benefits from aquatic resources, such as flood control, water quality enhancement, timber and forage production, recreation, fish September 1990 Page 56 ------- and wildlife habitat, groundwater recharge, shoreline protection, water storage, and natural greenbelts. Although considerable knowledge of the local impacts of human activities exists, documentation is not available on cumulative degradation across regions. Locally, urbanization, agriculture, silviculture, and grazing have greatly reduced the integrity of the landscape. These activities have altered the transport of water, soil, and chemicals to receiving waters and degraded essential aquatic and terrestrial habitat. Nationwide, habitat loss and declining fisheries also result from municipal, industrial, and agricultural activities, and various water development projects. Ambient biological monitoring has been underused to assess the extent to which regulatory and other efforts have had the desired effect in improving the quality of water resources. Our future policy challenge is to prevent further degradation of aquatic habitat and find ways to restore losses of past decades. COPING WITH MULTI-MEDIA POLLUTION Study after study demonstrates that air, water, and land resources are interconnected. Yet cross-media controls constitute one of the greatest remaining challenges of pollution control. Ten to 15 percent of the nitrogen entering Long Island Sound, for example, and as much as half the PCBs entering the Great Lakes may come from airborne emissions.51' 5Z Concentrating contaminants from wastewaters in treatment sludges and disposing them on or in the land may simply transfer pollution from surface to ground waters. Hater quality planning in the past often has been ineffective when based on political boundaries rather than watersheds or other appropriate geographic scales. A policy challenge is to find the broad perspective necessary to achieve effective ecosystem protection on a rational geographic basis. PROTECTING GROUNDWATER Significant gaps exist in comprehensive resource protection for groundwater. Yet groundwater is the repository of most human activities in and on the land such as farming, manufacturing, and transporting goods and people. Failed septic systems, leaking underground storage tanks, improper well construction, and infiltration from surface spills and runoff also are sources of September 1990 Page 57 ------- concern. According to surveys conducted by EPA, for example, 47 pesticides have been detected in groundwater in one or more wells in 26 states as a consequence of normal agricultural practices. It is questionable whether current groundwater protection authorities and programs will be sufficient to ensure the future safety of drinking water drawn from the ground. The challenge is to pursue a nationally consistent level of groundwater protection that respects ongoing local protection activities and allows locally efficient solutions to operate. INCREASING SCIENTIFIC UNDERSTANDING OF WATER QUALITY ISSUES In contrast to the hundreds of billions of dollars spent on facilities to remove pollutants before they enter the nation's waterways, relatively little has been spent to improve our understanding of the effects of pollution on humans and ecosystems at all levels of concentration. Credible measures of environmental results are largely unavailable. The effectiveness of many types of control measures has not been evaluated. A basic understanding of the values of aquatic ecosystems is lacking, as is a full understanding of the cumulative effects of human activities on these systems. Advanced methods to measure metals and organic contaminants in minute concentrations makes them easy to find in most surface and ground waters. But views conflict on the significance of on-going, low-level toxic contamination on human health or the environment and on the cost-effectiveness of controlling such contamination at the outer limits of detection. The challenge we face is to improve our understanding of the significance of contamination and the effectiveness of cleanup programs through improved sampling, testing for pollutants, and monitoring for the effects of point sources and runoff. This is impeded by the lack of effective ecological monitoring programs for aquatic resources. PROMOTING WISE USE OF RESOURCES Until recently, the by-products of industry, commerce, and everyday life have been treated largely as waste. Disposal of these by-products has put pressure on the quality of the nation's surface and ground waters. But as society has begun to increase the value it places on clean water resources, institutions and individuals September 1990 Page 58 ------- alike are finding new ways to use residuals productively, rather than dispose of them on the land or in the water. Similarly, because supplies generally have been plentiful, Americans have grown used to low prices for water with the predictable effect of excessive rates of use. In Europe, where water generally is scarcer than it is in the U.S., the average household pays roughly twice the average U.S.. price for drinking water and uses roughly half as much as we do in this country.54 A reduction in the quantity of clean water results directly from unwise use of resources. At some point, the higher prices that must be paid to cleanse water of residuals disposed in it could have a negative effect on lifestyles and dampen economic activity. The challenge for the future is to find ways of keeping materials cycling through the economy rather than allowing them to escape as waste. SETTING PRIORITIES Disagreements over the most important water quality problems hinder setting national priorities. Moreover, disagreements as to the relative importance of water quality problems versus other environmental issues also exist. At the heart of many of these differences are different perspectives on the criteria one might use to set environmental standards, agree on priorities, and allocate resources. EPA's Unfinished Business: A Comparative Assessment of Environmental Problems found, among other things, that one alternative way to set priorities is on the basis of relative risk. Using risk to set priorities may require a deeper understanding of both risk assessment and risk management-- two distinct concepts. Risk assessment is the science of determining what level of risk is posed by a given activity, such as the risk of cancer from exposure to a toxic pollutant in food or water. While the validity of various risk assessment methods is hotly debated, this is largely limited to scientific dispute. Risk management, on the other hand, involves extremely controversial policy issues such as what level of risk is "acceptable" for various activities as well as the feasibility of success within specified time frames or resource limitations. Opinions vary from those that argue that no risk from chemical pollution is acceptable, to those who point to the necessity of balancing risk to human and ecosystem health against the economic costs of September 1990 Page 59 ------- reducing risk. Most agree, however, that both regulators and the public need to achieve a better understanding of risk assessment. Even if scientists and policymakers improve their understanding of these issues, there may be little agreement on which kind of risk should be reduced. In Unfinished Business, for example, EPA identified four kinds of risk. The first two focused on relative risk to human health, including cancer health risks and non-cancer health risks. Some decisionmakers might prefer to minimize these risks. But EPA also found that there are two other measures of risk: the risk of ecological losses, such as elimination of environmentally sensitive species, and the risk of welfare losses, such as reduced opportunities for recreation or declining land values adjacent to polluted bodies of water. Moreover, some would argue that setting priorities on the basis of any kind of comparative risk is unwise. Neither public nor regulatory agencies, they argue, have sufficient information to understand fully human health risks or risks to ecosystems. In addition, risk assessment is resource intensive and may be an inefficient use of limited public resources. Our challenge is to improve our understanding of whether and to what extent risk analysis can contribute to priority setting or whether, for example, environmental priorities might be better established based on whole ecosystem effects, including consideration of all environmental media. PROVIDING SAFE DRINKING WATER The relationship between water quality and water quantity suggests that much of our activity designed to improve the quality of surface and ground waters will benefit drinking water supplies. For example, better planning to protect watersheds will ultimately reduce the cost to treat drinking water. Yet many issues regarding the provision of safe drinking water remain unresolved. For example, much of the cost of treating water to the standards required in the Safe Drinking Hater Act is currently shouldered by users—who are not necessarily the ones responsible for polluting drinking water sources. In addition, the expanded drinking water regulatory program presents a significant infrastructure problem, especially to small communities. These small systems generally have much higher costs of service because they lack the economies of scale needed to bring September 1990 Page 60 ------- treatment costs down. They also generally lack the management expertise to assure problem-free operation of relatively sophisticated treatment works or, indeed, to establish adequate pricing or billing systems. Moreover, small communities generally pay higher capital costs to borrow funds to build treatment works because they are unknown to most lenders and buyers of municipal bonds. In addition, some communities cannot afford the high fixed costs of borrowing through the bond market. Our challenge, therefore, is to acknowledge the benefits of high-quality drinking water, protect water supplies, develop technologies that deliver such supplies without harming other media, price the delivery of this resource to adequately reflect its value, and assure that all communities have access to and can pay for equally high-quality drinking water. MANAGING GROWTH AND DEVELOPMENT In many areas across the nation, urban and suburban sprawl is replacing forests, agricultural lands, and coastal and other natural areas at an alarming rate. Sprawling development increases surface areas exposed to disturbance, increasing storm water runoff and sedimentation and aggravating the risks of failed septic systems that pollute ground and surface waters. Such development forces the use of automobiles for most aspects of daily living, leading to increased highway development and causing more air pollution. The challenge we face is to manage and control growth in a way that respects watershed integrity and minimizes both direct and cumulative impacts of water quality. FINANCING HATER RESOURCE IMPROVEMENTS Central to all these water quality and resource issues is the question of funding. Finding adequate resources for water programs may be considerably more difficult in the future than it has been in the past. The dimensions of our funding challenge include: o Securing sources of funds from public and private sectors; o Allocating funds among competing environmental controls and monitoring of media; September 1990 Page 61 ------- o Managing funds effectively to address the full range of water quality problems; and o Evaluating the effects of funding programs in terms of public health and environmental results. September 1990 ------- V. THE NEXT STEP This report, which concludes Phase II of Water Quality 2000's work, contains findings regarding current and future water quality problems as articulated in the reports of ten work groups and in the deliberations of Water Quality 2000's Steering Committee and Member Congress. Water quality professionals from all levels of government, academia, industry, the professional community, and environmental interest groups contributed to these deliberations. This report has presented a profile of the current condition of the nation's water resources. It has described the sources currently impacting these resources and the importance of each relative to total impairment. Both causes of pollution and impediments to improving the physical, chemical, and biological integrity of the nation's waters have been discussed in detail. The report has characterized the root causes of water quality problems emanating from the fabric of our society. Impediments to solutions, in comparison, generally have been attributed to inadequacies of current water policies or programs. As water quality professionals representing all perspectives, the contributors to this report feel confident that it presents a balanced description of today's key water quality problems. We are confident that these conclusions will stand as a sound foundation for the formulation of solutions in the next phase of our work. We eagerly look forward to Phase III of our project and extend an invitation to all who wish to contribute to a continuing debate over solutions to support Water Quality 2000. September 1990 Page 63 ------- NOTES 1. U.S. Environmental Protection Agency, National Groundwater Supply Survey, Office of Drinking Water, June 1982. 2. National Council on Public Works Improvement, Frayte Foundations: A Report on America's Public Works, February 1988. 3. U.S. Environmental Protection Agency, Environmental Investments: The Costs of A Clean Environment, (forthcoming 1990) . 4. U.S. Environmental Protection Agency, National Water Quality Inventory, 1988 Report to Congress, Office of Water, March 1990. 5. U.S. Environmental Protection Agency, Toxic Release Inventory. 1988. 6. U.S. Environmental Protection Agency, National Survey, March 1988. 7. U.S. Environmental Protection Agency, National Water Qualify Inventory, 1988 Report to Congress, Office of Water, March 1990. 8. Judy, R.D., Jr., et al. 1984. 1982. National Fisheries Survey, Vol. I., "Technical Report: Initial Findings." FWS/OBS-84/06. U.S. Fish and Wildlife Service, Washington, D.C. 9. Miller, R.R., et al. 1989. "Extinctions of North American Fishes During the Past Century," Fisheries (Bethesda) 14:22-38. 10. U.S. Geological Survey, Testimony before House Public Works and Environment Committee, April 25, 1990. 11. U.S. Environmental Protection Agency, National Croundwater Supply Survey, Office of Drinking Water, June 1982. 12. There is some controversy regarding the definition of wetlands. According to federal regulations, an area is considered a wetland if it has certain soil, hydrologic, and biological conditions. In contrast, many define wetlands as marshes, swamps, bogs, and similar wet areas that are transitional between open water and dry land (uplands). The second definition would exclude many areas considered wetlands under federal regulations. September 1990 Page 64 ------- 13. U.S. Fish and Wildlife Service, Wetland Lasses in the United States, 1970s to 1980s, A Report to Congress, U.S. Department of the Interior, Washington, D.C., July 1990. 14. Williams, J.E. et al. 1989. "Fishes of North America- Endangered, Threatened, or of Special Concern," Fisheries (Bethesda) 14:2-20. 15. Ebel, W.J. et al. 1979. "The Columbia River: Toward a Holistic Understanding." Pages 205-19 in D.P. Dodge, ed. Proceedings of the International Large Rivers Symposium. Canadian Special Publication of Fish and Aquatic Sciences. 16. Sport Fishing Institute, Aquatic Contaminants: A Threat to the Sport Fishing Industry, Washington, D.C., 1986. 17. U.S. Environmental Protection Agency, National Water Quality Inventory, 1988 Report to Congress t Office of Water, March 1990. 18. Congressional Budget Office, Environmental Regulation and Economic Efficiency, March 1985. 19. U.S. Bureau of the Census, Government Finances Series, various years. 20. Environmental Protection Agency, 1988 Needs Survey, Office of Water, February 1989. 21. U.S. Environmental Protection Agency, A Preliminary Analysis of Public Costs of Environmental Protection:1981-2000, Office of Administration and Resources Management, May 1990. 22. U.S. Environmental Protection Agency, State Funding Study-Draft Recommendations, Office of Water, 1989. 23. U.S. Environmental Protection Agency, 1988 Needs Survey, Office of Water, February 1989. 24. National Council on Public Works Improvement, Fragile Foundations, February 1988. September 1990 Page 65 ------- 25. U.S. Environmental Protection Agency, National Water Quality Inventory, 1988 Report to Congress, Office of Water, March 1990. 26. U.S. Department of Health and Human Services, Evaluating the Environmental Health Work Force, prepared by Levine and Associates, Rockville, MD, January 1988. 27. Richard C. Atkinson, "Supply and Demand for Scientists and Engineers: A National Crisis in the Making," Science, April 27, 1990. 28. U.S. Bureau of Labor Statistics as cited in Robert Pool, "Who Will Do Science in the 1990s?" Science, April 27, 1990. 29. Personal communication with Steven Moehlmann, Executive Director, Association of Boards of Certification, May 30, 1990. 30. Association of Boards of Certification, "Operator Certification: 1980 Status Report," Journal of the Water Pollution Control Federation, December 1981. 31. USAToday, April 20, 1990. 32. Cambridge Reports, Trends and Forecasts, September 1989. 33. Institute of Public Administration, Special Districts and Public Authorities in Public Works Provision, prepared for the National Council on Public Works Improvement, July 10, 1987. 34. Commuting in America, The Eno Foundation, 1988. 35. U.S. General Accounting Office, Environmental Protection Agency: Protecting Human Health and the Environment Through Improved Management, August 1988. 36. U.S. Environmental Protection Agency, State Funding Study—Draft Recommendations, Office of Water, 1989. 37. Many of these systems, such as those that serve mobile home parks, recreation areas, or institutions, are not in continuous use by the public. September 1990 Page 66 ------- 38. For details, see Environmental Financial Advisory Board to the U.S. Environmental Protection Agency, Statement an Environmental Tax Polity, Draft, March 1990. 39. U.S. Environmental Protection Agency, Report to Congress, Water Quality Improvement Study, Office of Water Regulations and Standards, September 1989. 40. U.S. Environmental Protection Agency, A Preliminary Analysis of the Public Costs of Environmental Protection: 1981-2000, Office of Administration and Resources Management, May 1990. 41. This estimate may overstate shortfalls, to the degree that states leverage their capitalization grants. See: National Council on Public Works Improvement, The Nation's Public Works: Report on WastewaterManagement, prepared by Apogee Research, Inc., May 1987. 42. American Society of Civil Engineers, Civil Engineering in the 21st Century, 1988. 43. National Science Foundation, Science and Engineering Indicators -1989, 1989. 44. Richard 6. Luthy and Mark M. Benjamin, "Solving Groundwater Contamination Problems Through Graduate Education in Environmental Engineering," Water Environment and Technology, January 1990. 45. Testimony of John Neuhold before the House of Representatives' Science, Space, and Technology Committee, Subcommittee on Natural Resources, April 3, 1990. 46. Richard C. Atkinson, "Supply and Demand for Scientists and Engineers: A National Crisis in the Making," Science, April 27, 1990. 47. see Atkinson, 1990. 48. Paul L. Busch and William C. Anderson, "Education of Hazardous Waste Engineering Professionals," presented at the 116th Annual Meeting of the American Public Health Association, Boston, Massachusetts, November 15, 1987. 49. National Science Foundation, Science and Engineering Indicators • 1989, 1989. September 1990 Page 67 ------- 50. See Testimony of John Neuhold, April 3, 1990. 51. Long Island Sound Study Policy Committee, Long Island Sound Study 1988 Annual Report. 1989. 52. Great Lakes Water Quality Board, Report to the International Joint Commission, The 1987 Report on Great Lakes Water Quality, Windsor, Ontario, 1987. 53. U.S. Environmental Protection Agency, Pesticides in Ground Water Data Base, 1988 Interim Report, Washington, D. C., 1988. 54. Peter Rogers and Kenneth I. Rubin, "Management of Water Resources in the U.S.: Current Context and Future Strategies," presented at the Institute of Public Administration of Canada's Conference on Management of Water Resources, Harrison Hot Springs, B.C., April 24-26, 1985. September 1990 Page 68 ------- APPENDIX A Organization, Goal, and Mission of Water Quality 2000 Water Quality 2000 was initiated in 1988. In July of that year, leaders of 26 national, state, and local organizations met to assess the effectiveness of current water quality policies, the process by which these policies are established, and ways in which this process could be improved. At the conclusion of the conference, an ad hoc committee was formed to explore the feasibility of a formal cooperative effort. This ad hoc group developed a mission statement, agreed upon a vision and goal, and created an or- ganizational structure for the effort. These documents were refined and ratified by representatives of 31 organizations. Mission Statement The mission of Water Quality 2000 is stated as follows: Representing a broad range of interests in America, propose and promote national policies and goals for the 21st century that will protect and enhance water quality, with a specific agenda for action. In carrying out this mission, the following principles will be applied: • Broad representation will be achieved; • The perspective will be long-range, visionary, and holistic; • Maximum consensus on "national principles" will be sought; • Water quality, not water quantity, is the focus, but with a balanced view of surface, ground, and atmospheric waters; and • The product of Water Quality 2000 will include a specific agenda for action. Membership and Governance To date, membership in Water Quality 2000 has included more than 80 organizations, representing industry, government, the environmental movement, the professional and technical community, and academia (see Appendix B for a list of Member Organizations). Membership is balanced to reflect the diversity of interests concerned with water quality. Each organization has an equal voice in the Member Congress (except that federal agency members do not vote). A twenty-member Steering Committee, September 1990 Page 69 ------- elected in September 1989, provides overall leadership and direction for Water Quality 2000 (see Appen- dix C for a list of Steering Committee members and their affiliations). Water Quality 2000 is a Four-step Process The work plan approved at the 1989 conference divides the activities of Water Quality 2000 into four distinct phases (see box). Phase I, Feasibility and Plan Development, was completed in May 1989. The adoption of this report completes Phase ft Problem Identification. This report assesses the current con- dition of the nation's water resources, explores the underlying causes of water problems, critiques the policies and programs in place to deal with these problems, and identifies impediments to their solu- tion. In doing so, it provides the foundation for Phase ffl, Development of Recommendations. This next phase of the project will seek consensus on policy recommendations that correspond to the problems identified in this report. These recommendations will be completed in 1991. During Phase IV, Im- plementation, Water Quality 2000 will publicize and explain these recommendations to Congress and all who influence water quality. The Four Phases of Water Quality 2000 Phase I — Feasibility and Plan Development Phase n — Problem Identification Phase QI — Development of Recommendations Phase IV — Implementation Methodology for Problem Identification To provide the broadest possible perspective on problems with current policies and programs, ten work groups of 15 to 25 members were established (see box). Efforts were made to ensure a balanced membership that would reflect the diverse composition of those concerned with water quality. Work groups were asked to arrive at their conclusions by a process of discussion, debate, and consensus. Over 150 individuals participated in the work group process between August 1989 and May 1990 (a list of work group participants is attached as Appendix D). September 1990 Page 70 ------- The Ten Work Groups Convened During Phase II • Agriculture • Aquatic Ecosystems and Habitat • Community • Energy and Resources Extraction • Industry • Legislation • Recreation • Transportation • Watershed • Water Supply The groups were charged with identifying the most critical water quality issues in each area of con- cern. The groups were asked to approach this task in a visionary and futuristic manner, measuring cur- rent conditions against the Water Quality 2000 Vision Statement and Goal (see Appendix E for the full text of both). Each group addressed three broad topics: (1) water quality problems; (2) causes of these problems; and (3) impediments to solutions. Draft reports from each work group were circulated for review by all Member Organizations. Com- ments submitted as a result of this review were considered by the groups in developing their final reports. The Steering Committee reviewed the ten reports, used them to develop this document, and in some cases, augmented them. This report — the official product of Phase n — synthesizes the findings of the ten work groups, identifies major themes and oosscutting issues, and provides a framework for the consideration of solutions in Phase m. September 1990 Page 71 ------- APPENDIX B Water Quality 2000 Member Organizations Academy of Natural Sciences of Philadelphia American Academy of Environmental Engineers American Association of Port Authorities American Association of State Highway and Transportation Officials American Consulting Engineers Council American Farm Bureau Federation American Farmland Trust American Forestry Association American Institute of Chemical Engineers American Paper Institute/National Forest Products Association American Petroleum Institute American Planning Association American Public Works Association American Recreation Coalition American Rivers American Society of Civil Engineers American Water Resources Association American Water Works Association Association of Environmental Engineering Professors Association of Metropolitan Sewerage Agencies Association of Metropolitan Water Agencies Association of State Drinking Water Administrators Chemical Manufacturers Association Chesapeake Bay Foundation Citizens For A Better Environment, California Colorado Environmental Coalition The Conservation Foundation Edison Electric Institute Environment and Energy Study Institute Environmental Defense Fund Environmental Law Institute The Fertilizer Institute Friends of the Earth Green Bay Metropolitan Sanitary District (Wisconsin) Great Lakes Commission Harvard University - Division of Applied Sciences Heidelberg College - Water Quality Laboratory International City Management Association Interstate Commission on the Potomac River Basin Izaak Walton League of America Kansas Water Office Legal Environmental Assistance Foundation September 1990 Page 72 ------- Lower Colorado River Authority (Texas) Michigan Department of Natural Resources National Agricultural Chemicals Association National Association of Conservation Districts National Association of Counties National Association of Regional Councils National Association of State Universities and Land Grant Colleges National Association of Stormwater and Hood Management Agencies National Association of Water Companies National Food Processors Association National League of Cities National Parks and Conservation Association National Recreation and Parks Association National Society of Professional Engineers National Wildlife Federation Natural Resources Defense Council North American Lake Management Society NSI Technology Services, Inc. Occidental Petroleum Corporation Reliance National Insurance Company Rock River Water Reclamation District Rural Community Assistance Program Soil and Water Conservation Society Spill Control Association of America Sport Fishing Institute Trout Unlimited Urban Land Institute United Shipowners of America U.S. Army - Corps of Engineers U.S. Dept. of Agriculture Agricultural Research Service Forest Service Soil Conservation Service U.S. Dept. of Commerce - NOAA/National Marine Fisheries Service U.S. Dept. of Interior Bureau of Reclamation Fish and Wildlife Service Geological Survey U.S. Dept. of Transportation U.S. Environmental Protection Agency Vanderbilt University Virginia Polytechnical Institute and State University Water Pollution Control Federation Water and Wastewater Equipment Manufacturers Association Wisconsin Wildlife Federation September 1990 Page 73 ------- APPENDIX C Water Quality 2000 Steering Committee Members and Their Affiliations Bob Adler (Vice Chairman) Natural Resources Defense Council Judy Campbell Bird Environment and Energy Study Institute Brenda Cuccherini Chemical Manufacturers Association Clifton Curtis The Oceanic Society (9/89-7/90) John Doyle (9/89-3/90) G. Edward Dickey (3/90-) U.S. Army Corps of Engineers Clark Duffy Kansas Water Office Linda Eichmiller Association of State and Interstate Water Pollution Control Administrators (9/89-6/90) Nancy Foster NOAA/National Marine Fisheries Service Chuck Fox Friends of the Earth Frank Friedman Occidental Petroleum Corporation Margot Garcia American Planning Association Jerome Gilbert American Academy of Environmental Engineers Mack Gray USDA /Soil Conservation Service Patricia Hill American Paper Institute/National Forest Products Association Carolyn Olsen Association of Metropolitan Sewerage Agencies Ruth Patrick The Academy of Natural Sciences Ann Powers Chesapeake Bay Foundation Rudy Rosen (7/90-) National Wildlife Federation David Stahl Urban Land Institute Ernest Shea National Association of Conservation Districts Paul Woodruff (Chairman) Water Pollution Control Federation Steering Committee Alternates Walter Bishop, alternate for Jerome Gilbert Jim Burt, alternative for Mack Cray Stan Chanesman, alternate for Nancy Foster Jessica Landman, alternate for Bob Adler Ernie Rosenberg and Catharine deLacy, alternates for Frank Friedman September 1990 Page 74 ------- APPENDIX D Water Quality 2000: Work Group Participants AGRICULTURE American Forestry Association Gerald Gray American Society of Civil Engineers William R. Johnston Association of State and Interstate Water Pollution Control Administrators Linda Eichmiller Chesapeake Bay Foundation Patrick Gardner Environmental and Energy Study Institute Judy Campbell Bird Farmer, Casselton, North Dakota Robert Sinner Fertilizer Institute (The) Karl Johnson Heidelberg College, Water Quality Laboratory David Baker Lower Colorado River Authority (Texas) John Hall Kolleen Wilwerding National Agricultural Chemicals Association Thomas Gilding National Association of Conservation Districts Ernest Shea National Association of State Universities and Land Grant Colleges Terry Nipp National Association of Wheat Growers Margery Williams National Com Growers Association David Stawick National Food Processors Association Paul Halberstadt National Research Council, Board on Agriculture Craig A. Cox Natural Resources Defense Council Thomas Kuhnle Justin Ward Soil and Water Conservation Society Norman Berg Richard Duesterhaus U.S. Department of Agriculture Richard Amerman, Agriculture Research Service Ronald F. Follett, Agricultural Research Service Mack Gray, Soil Conservation Service Doral Kemper, Agriculture Research Service Jack McDougle, Soil Conservation Service Peter Patterson, Soil Conservation Service Marc Ribaudo, Economic Research Service Ed Schlatterer, Forest Service Peter Smith, Soil Conservation Service Mark Waggoner, Soil Conservation Service U.S. Environmental Protection Agency Robert Barles, Office of Water Robert Bastian, Office of Water Peter Caulkins, Office of Policy, Planning and Evaluation Rosanna Ciupek, Office of Water Rebecca Hanmer, Office of Water (Chair) James J. Jones, Office of Policy Analysis Jeanne Melanson, Wetlands Protection Carl Myers, Office of Water Clayton Ogg, Office of Policy, Planning and Evaluation John Reeder, Office of Water Lynn Shuyler, Chesapeake Bay, Region m September 1990 Page 75 ------- AQUATIC ECOSYSTEMS AND HABITAT Environmental Defense Fund Rodney Fujita Mary Voytek Green Bay Metropolitan Sanitary District (Wisconsin) Harold Day John Kennedy National Council for Air and Stream Improvement Dennis Borton National Oceanic and Atmospheric Administration Stan Chanesman, National Marine Fisheries Service National Wildlife Federation Rudy Rosen NSI Technology Services Corporation Robert Hughes Oceanic Society Boyce Thome Miller Sport Fishing Institute Gilbert Radonski US. Army Corps of Engineers Mary Landin, Waterways Experiment Station VS. Department of Agriculture Gordon Haugen, Forest Service VS. Department of Interior Mary Gessner, Fish and Wildlife Service VS. Environmental Protection Agency David Davis, Office of Wetlands Protection James Giattina, Water Division, Region V (Chair) Charles Sutfin, Water Division, Region V Virginia Polytechnic Institute and State University James Karr Wisconsin Department of Natural Resources Scott Hausmann Woolpert Consultants Warren High September 1990 Page 76 ------- COMMUNITY American Academy of Environmental Engineers Walter J. Bishop American Consulting Engineers Council Pat Marchese American Planning Association, Virginia Commonwealth University Margot W. Garcia American Public Works Association Richard Sullivan Association of Metropolitan Sewerage Agencies Ken Kirk Association of State and Interstate Water Pollution Control Administrators Chuck Evans Citizens for a Better Environment, California Denise Fort City of Atlanta, Department of Water and Pollution Control George Barnes Carolyn Hardy Olsen City of San Diego (California) Susan C. Hamilton City of Tulsa (Oklahoma) Lloyd C.Coffelt Bob Pool Green Bay Municipal Sanitary District (Wisconsin) Harold J. Day Louisville and Jefferson County Metropolitan Sewer District (Kentucky) Bud Schardein Lower Colorado River Authority (Texas) David Freeman Municipality of Metropolitan Seattle (Washington) John B. Lampe National Association of Regional Councils Richard Hartman National League of Cities Carol Kocheisen Natural Resources Defense Council BobAdler Jessica Landman Passaic Valley Sewerage Authority (New Jersey) Carmine T. Perrapato Philadelphia Water Department (Pennsylvania) Dean A. Kaplan Puget Sound Water Quality Authority (Washington) Kathy Fletcher Rock River Water Reclamation District Ron Holm Jon Olson (Chair) U.S. Department of Agriculture, Forest Services Gordon Stuart U.S. Environmental Protection Agency, Office of Municipal Pollution Control Mike Quigley September 1990 Page 77 ------- ENERGY AND RESOURCE EXTRACTION AMAX Peter Keppler American Petroleum Institute Stephanie Meadows Columbia Law School Frank Grad Edison Electric Institute Rich Bozek Environmental Law Institute BUI Futrell Jim McElfish National Wildlife Federation Cathy Carlson Natural Resources Defense Council Lisa Spear Occidental Petroleum Corporation Frank B. Friedman (Chair) Catharine deLacy Ernie Rosenberg US. Department of Agriculture Doreen Christian, Forest Service US. Environmental Protection Agency Mahesh Podar, Office of Policy Analysis John W. Wilson, Office of Policy, Planning, and Evaluation Western Governors Association Philip Shimer INDUSTRIAL American Consulting Engineers Council Eric Lappala American Electroplaters and Surface Finishers Society Erich Salomon American Paper Institute/National Forest Product Association Patricia Hill (Co-chair) Chemical Manufacturers Association Jim Baker Brenda Cuccherini Citizens For A Better Environment, C A Denise Fort Colorado Environmental Coalition Ross Vincent Edison Electric Institute Rich Bozek Environmental Defense Fund Ann Maest Natural Resources Defense Council Diane Cameron US. Department of Agriculture Richard Cline, Forest Service US. Environmental Protection Agency Mark Luttner, Industrial Technology Water Pollution Control Federation Eugene DeMichele Carl Huber (Co-chair) Michael Saunders LialTischler September 1990 Page 78 ------- LEGISLATION American Association of Environmental Engineers Walter]. Bishop Jerome B. Gilbert American Petroleum Institute Stephanie Meadows American Water Resources Association Alfred Duda Madge Ertel Association of Metropolitan Sewerage Agencies Kevin McCarty Association of Metropolitan Water Agencies Diane VanDe Hei Association of State and Interstate Water Pollution Control Administrators Linda Eichmiller Chemical Manufacturers Association Dell Perelman Congressional Research Service Claudia Copeland Environmental Law Institute Lisa St. Amand Friends of the Earth Chuck Fox Great Lakes Commission Michael Donahue Harvard University Peter Rogers Izaak Walton League of America David Dickson National Agricultural Chemicals Association Jean Toohey National Association of Conservation Districts Steve Meyer National League of Cities Carol Kocheisen Natural Resources Defense Counci Jessica Landman (Co-chair) US. Department of Agriculture Warren Harper, Forest Service US. Environmental Protection Agency Don Brady, Office of Water Regulations and Standards Martha Prothro, Office of Water (Co-chair) Linda Wilbur, Office of Water Regulations and Standards Wastewater Equipment Manufacturers Association Dawn Kristof September 1990 Page 79 ------- RECREATION American Fisheries Society Paul Brouha American Fishing Tackle Association Dallas Miner American Recreation Coalition Derrick Crandall American Rivers, Inc. Susan Wilkins Living Lakes Tim Adams National Recreation and Parks Association Barry Tindall New York State Department of Environmental Conservation Ron Miller North American Lake Management Society Jerry Filbin Resources for the Future Carol Jones Soil and Water Conservation Society Mel Bellinger Sport Fishing Institute Gilbert Radonski Trout Unlimited Bob Herbst (Co-chair) U.S. Department of Agriculture Elizabeth Estill, Forest Service (Co-chair) US. Department of Commerce Wylie Whisonant, Jr. U.S. Environmental Protection Agency Mary Jo Kealy, Economic Analysis Ralph (Skip) Luken, Economic Analysis Brett Snyder, Economic, Analysis George Walker, Chesapeake Bay Program Wisconsin Wildlife Federation Ray Felton TRANSPORTATION American Association of Port Authorities Joseph Birgeles Richard Gorini (Co-chair) American Association of State Highway and Transportation Officials Francis Francois Mel Thomas Great Lakes Commission Michael Donohue Steve Thorp National Association of Dredging Contractors Mark Sickles National League of Cities Nicholas Yaksich Oceanic Society Clifton Curtis Spill Control Association of America Marc K. Shaye U.S. Army Corps of Engineers David Barrows Robert Engler Dave Mathis U.S. Department of Agriculture David Badger, Forest Service U.S. Department of Transportation Joseph F. Canny (Co-chair) Larry Isaacson U.S. Environmental Protection Agency Ken Mittelholtz, Office of Federal Activities Vanderbilt University Edward L Thackston, Department of Civil and Environmental Engineering Water Pollution Control Federation Walter A. Lyon September 1990 Page 80 ------- WATERSHED American Public Works Association Pam Bissonnette American Water Resources Association Raymond Herrmann, National Park Service (Co-chair) Charles Mosher, US. General Accounting Office Association of State and Interstate Water Pollution Control Administrators Linda Eichmiller Chesapeake Bay Foundation Ann Powers Interstate Commission on the Potomac River Basin Roland Steiner Kansas Water Office Clark Duffy NSI Technical Services Andrew Kinney University of Michigan Jonathan Bulkley, Natural Resources and Civil Engineering University of Washington Dennis Lettenmaier, Department of Civil Engineering U.S. Department of Agriculture Karl Otte, Soil Conservation Sendee US. Department of the Interior Stephen Ragone, Geological Survey (Co-chair) U.S. Environmental Protection Agency Thomas Davenport, Nonpoint Sources, Region V Tudor Davies, Office of Marine and Estuarine Protection Michelle Hiller, Office of Marine and Estuarine Protection WATER SUPPLY American Planning Association Margot Garcia American Water Works Association John Sullivan Edward Tenny (Chair) Association of Drinking Water Administrators G. Wade Miller Association of Metropolitan Water Agencies Diane VanDe Hei City of Portland, Bureau of Water Works Jeanne McCormick Environment and Energy Study Institute Janet Edmond National Association of Towns and Townships Amie Edelman National Association of Water Companies Jim Groff National Rural Water Association John Trax Philadelphia Water Department Dean Kaplan University of North Carolina Daniel Okun (retired) U.S. Department of Agriculture Warren Harper, Forest Service US. Environmental Protection Agency Mike Cook, Office of Drinking Water Joe Cotruvo, Office of Health and Environmental Review Water and Wastewater Equipment Manufacturers Association Dawn Kristof September 1990 Page 81 ------- APPENDIX E Water Quality 2000: Vision Statement and Goal Vision Statement: Society living in harmony with healthy natural systems. Goal: To develop and implement and implement an integrated policy for the Nation to protect and enhance water quality that supports society living in harmony with healthy natural systems. To achieve this goal, this policy should CONSIDER: • all phases of the water cycle, including groundwater, surface water, and atmospheric water; • water as one part of a total environmental management plan, to avoid transferring problems from one environmental medium to another; • the link between water quality and land use; • the relationship between water quality policy in the United States and global environmental issues; • the need to maintain a healthy economy. PROMOTE SUCH STRATEGIES AS: • source reduction and waste minimization; • water conservation and reuse; ASSURE: • healthy aquatic, estuarine and marine ecosystems; • healthy drinking water supplies and adequate water quality for other uses; • protection of human health from water quality hazards associated with recreation, fish and shellfish consumption, and other water uses. Adopted 5/19/89 September 1990 " Page 82 ------- APPENDIX F Summaries of Work Group Reports The attached documents are summaries of Water Quality 2000*5 ten Phase n work group reports. These work groups included more than 150 environmental professionals. These summaries are products of the individual work groups and may not reflect the views of the Water Quality 2000 Steer- ing Committee or the participating organizations. The Steering Committee used the work groups' full reports as background for this Phase D report. Copies of the full reports of the work groups are available on request from Tim Williams, Water Quality 2000,601 Wythe Street, Alexandria, Virginia, 22314-1994, (703) 684-2416. We wish to thank all the work group participants for their efforts and look forward to their con- tinued contribution in Phase HI of Water Quality 2000. September 1990 Page 83 ------- Agriculture Work Group Executive Summary In many areas of the United States, agricultural pollution creates water quality problems that result in ecological damage, economic losses and health risks for humans and livestock. Termed "nonpoint," agricultural and other diffuse sources of pollution are increasingly viewed as important environmental problems. The Agriculture Work Group's Phase II Report identifies sources of agricultural pollution — soil erosion and sediment, nutrients, irrigation, conversion and loss of wetlands and riparian habitat, pes- ticides and animal production — and discusses the scope of the problems and impediments to solving them, including costs of management practices, gaps in information and institutional impediments. Scope of the Problems Surface Water Assessments by states under Section 319 of the Clean Water Act and sampling by the U.S Geological Survey provide considerable insight into pollution problems. More than half of the nation's rivers and lakes have yet to be assessed, but, of those that have been studied, a third of the river miles and a fourth of the lake acres were found to be impaired for some designated uses. Polluting sources include: • Sediment from agriculture and other nonpoint sources, which accounted for 42 percent of the impaired river miles, while pesticides accounted for 10 percent. Economic studies place costs of sediment damages in the billions of dollars per year. • Nutrients accounted for 49 percent, sediment for 25 percent and pesticides for five percent of impaired lake acres. More recent findings suggest that pesticides occur in surface waters, including drinking water, more widely than previously realized. • Agriculture accounts for 70 percent of phosphorus loadings, which are often the limiting nutrient for lake eutrophication problems. Sediment and animal wastes are major contributors to phosphorus loadings; animal wastes can also cause serious localized pathogen problems. • Agricultural practices have destroyed a large amount of wetlands and have damaged vegetation on streambanks, eliminating areas that filter sediment and nutrients and provide many other ecological benefits. September 1990 Page 84 ------- In several western states, irrigation-related damage from salt costs downstream urban, industrial and agricultural water users hundreds of millions of dollars yearly. Irrigation can also leach toxic chemi- cals into surface waters and groundwater. Groundwater Less is known about the affect of agricultural practices on groundwater. Nitrates in groundwater ex- ceed current health standards levels in virtually all states and occur in 5 to 20 percent of sampled wells in the Western Corn Belt and Mid-Atlantic states. Pesticides have also been found in groundwater in most states; however, pollution levels are usually below health advisory standards of contamination. • A primary cause of nitrate problems is poor synchronization of nitrogen supply with crop needs. • The lack of data on health risks from consuming nitrate-nitrogen and pesticides, especially for low levels of concentration, complicates assessments. Impediments to Solving Problems Economic Impediments Agricultural producers are driven by the profit motive, therefore economic realities determine, to a large extent, the way they run their farms. • Agricultural producers are generally subject to substantial risks for which they receive relatively small returns. Significant impediments to reducing agricultural pollution include the unavailability of technical expertise and perceived or actual economic risks associated with adopting more environmentally oriented farming practices. However, alternative methods of farming that reduce production costs may stimulate the adoption of more water quality protection practices. • Because they operate within a competitive system, individual farmers are generally unable to pass the incremental costs of environmental remediation on to consumers, which reduces their ability to adopt best management practices (BMPs) economically. • Increased agricultural productivity across the U.S. has intensified fanning practices. When chemicals are used and livestock are concentrated in small areas, the increase in wastes and related pollutants elevates the risks of water pollution. This kind of intensified agriculture poses a serious challenge to improving water quality. September 1990 Page 85 ------- Political Impediments Farmers are strongly affected by government at all levels. Some government programs have already been modified to support wetland preservation and soil conservation, with a greater emphasis on at- taining water quality goals. Nonetheless, the work group identified gaps in these efforts and conflicts with environmental goals. • Farm programs often inadvertently operate to frustrate or undercut environmental policies by encouraging intensive production that, at times, occurs on environmentally sensitive lands. Current program rules that base payments on recent planting of grains encourage monoculture at the expense of crop rotations that may require the use of fewer pesticides and increase the benefit to the soil. This problem has been recognized, and there are a number of legislative proposals under consideration in the U.S. Senate and House of Representatives. • Even with the expansion and targeting of soil conservation expenditures based on control of erosion, a remaining impediment is the difficulty of coordinating these federal soil conservation programs with state-led programs to improve water quality. • State water quality programs are beginning to address agricultural nonpoint source issues. However, much work remains to be done on water quality standards, localized risk assessments and management planning. • Mandatory environmental regulations often exempt agriculture, reflecting a general preference for voluntary programs. Reliance on voluntary approaches makes it difficult to target remediation efforts to the worst problems. Continued reliance on voluntary programs without increased government funding is a key impediment to achieving national water quality goals. • The lack of resources for controlling nonpoint source pollution, generally, and agricultural pollution, in particular, is a serious impediment. Information-related Impediments Effective water quality protection programs require sufficient data to establish goals, fix respon- sibility and design and implement pollution abatement practices. The work group identified a number of information impediments. September 1990 Page 86 ------- • Since agricultural pollution emanates from millions of locations, the states and the federal government have been unable to pinpoint the absolute and relative contributions of various sources. This has impaired government's ability to design effective remediation programs based on area-specific water quality objectives. • There is incomplete farm-level information on water quality BMPs and alternative agricultural systems. For example, data are needed for quantifying the effectiveness of different kinds of BMPs, and dissemination of the substantial knowledge that does exist is limited. • Data gaps for many pesticides include information on health risks, especially at low levels, risks from break-down products and risks from exposure to multiple pesticides. There are significant gaps in data on pesticide-use patterns and the extent of surface water and groundwater contamination. • Additional information on nitrates is needed for more comprehensive soil tests and related data to allow fanners to meet but not exceed plant nitrogen requirements; improved methods for irrigation water management to reduce leaching; and data on health effects, especially on cancer risks. September 1990 Page 87 ------- Aquatic Ecosystems and Habitat Executive Summary The Aquatic Ecosystems and Habitat Work Group was assigned the task of describing the ecological effect of human activities that degrade this nation's freshwater, estuarine and marine surface water resources. To accomplish this task, we looked beyond water quality from a purely chemical standpoint and examined the full range of physical, chemical and biological factors that contribute to the degrada- tion of aquatic ecosystems. In doing so, the work group concluded that aquatic resource management programs have not used biological indicators — such as the health of aquatic organisms and the ter- restrial life that depends on these organisms — to identify problems and develop solutions and there- fore have failed to adequately protect the biological aspects of those resources. The result of this over- sight is a fragmented and, at times, contradictory approach to aquatic resource management. Scope of the Problems Aquatic ecosystems have been degraded and destroyed by a broad range of human activities that have occurred locally, regionally and globally. In particular, urbanization, agriculture, silviculture and livestock grazing have drastically altered the integrity of the landscape, resulting in runoff of soil and chemicals to receiving waters and affecting essential aquatic and terrestrial habitat. Further, alterations of waterways (damming, channeling, sedimentation and mining) and water withdrawal for human con- sumption and agricultural and industrial use have altered and eliminated important habitats and destroyed major fisheries. Population growth and the resultant disposal of wastes and by-products of human activities has led to extensive toxic contamination of water and sediment, creating lethal conditions for aquatic life and threatening human health. Finally, overharvest of fish and shellfish resources and introductions of species have altered native aquatic communities, often reducing natural biological diversity. Evidence is mounting that disparate impacts are cumulatively resulting in alterations worldwide such as global warming and ozone depletion. In addition, pristine environments are jeopardized by the atmospheric transport of pollutants. Work Group Recommendations To reverse this history of aquatic resource degradation, the Aquatic Ecosystems and Habitat Work Group urges the Water Quality 2000 Member Congress to adopt the goals of achieving no net loss of the functions and values of aquatic ecosystems and expanding the resource base by restoring damaged aquatic ecosystems. The Member Congress should then encourage the immediate adoption and im- September 1990 Page 88 ------- plementation of these goals by federal and state executive order and, ultimately, should work toward their adoption as national policy in all federal and state legislation affecting aquatic ecosystems. To effectively work towards the achievement of these goals, we must better understand and protect the structural and functional integrity of aquatic ecosystems, attributes that are intimately related to the values of those systems, and recognize the cumulative, degrading effect of seemingly disparate, and often minor, impacts. Furthermore, we must be more aware of the potentially destructive ecological af- fects of human actions while addressing equally complex social and economic problems. The factors responsible for the massive degradation of aquatic resources can often be identified. Al- though we know how to reverse some trends towards resource degradation, other trends seem to be ir- reversible. As a society, we must engender understanding and respect for natural resources. By foster- ing enhanced stewardship through knowledge, we can gamer the public mandate and financial resources to ensure the continued existence of pristine environments (Le. areas virtually unimpacted by human actions), healthy aquatic and marine ecosystems and sustainable aquatic resources. September 1990 Page 89 ------- Community Work Group Executive Summary A community's water quality can be affected by waste management problems that create ongoing, cross-media pollution. The Community Work Group identifies these water quality problems by physi- cal sources—effluent discharges, surface runoff, groundwater pollution and air pollution—and ex- amines the problem of resources lost or wasted as a result of certain community water use and waste disposal practices. Finally, the work group discusses the political, financial and cultural impediments that community decisionmakers and officials will face when they attempt to solve water quality problems. Scope of the Problems Effluent Discharge Communities discharge trillions of gallons of effluent each year after treating wastewater from homes, businesses and industries that release their wastes into public sewers. If inadequately treated, the effluent received into waters will produce problematic levels of suspended solids, nutrients and toxics and cause a wide range of health and environmental problems. • A U.S. Environmental Protection Agency (EPA) survey taken in 1988 indicated that almost 70 percent of the nation's treatment and collection facilities had caused documented water quality problems. Therefore it is reasonable to suspect that the existing publicly owned treatment works will experience additional difficulties as they attempt to cope with the volume and composition of sewage generated by communities in the 21st century. • Treatment-induced problems generated through processes such as dechlorination and disinfection through chlorination can be significant, as the final effluent may contain unacceptable levels of toxics. Community discharge can also introduce nontoxic problems such as turbulence and temperature disparity into the receiving waters. • Pretreatment can leave waste generators with highly toxic sludge residues that, if not disposed of properly, harm water quality. Additional problems result when pretreatment programs are delegated to the local level where enforcement ordinances are sometimes weak. September 1990 Page 90 ------- • Combined sewer overflows are problematic in times of wet weather when combined sewer flow, possibly containing unacceptable pollutants, is discharged directly into receiving waters. Older cities, especially in the northeastern U.S., are often served by combined sewers. Surface Runoff Materials placed on the land or erosion from land development become major contributors to water quality problems when surface water runoff carries them into waterbodies. • Pollution assimilated from a variety of sources on community surfaces can contaminate receiving waters. Such runoff includes asbestos and lubricants from roads, materials from construction sites and fertilizers and pesticides from lawns. Runoff from agricultural impoundments, golf courses and domestic plots can also contain toxics and problematic levels of nutrients. • Environmental changes can result in nonpollutant water quality problems. Construction activities, for instance, can increase sediment runoff to receiving waters and thus block sunlight to biota, clog fish gills and disturb spawning beds. Drainage system modification, floodplain development and wetland development can adversely alter a system that once efficiently removed many pollutants and controlled hydrological patterns. • Planning and land use decisions contribute to water quality problems if made without consideration of geographic impacts. Examples of such decisions include insufficient setbacks from waterbodies, excess densities and high intensity land uses near sensitive waters. Groundwater Pollution The integrity of the nation's groundwater is threatened by landfilling of solid and hazardous wastes and sludges, badly maintained septic systems and deteriorating sewage collection and treatment facilities. • Moisture leaching through landfills can contaminate groundwater. Although landfill lining can reduce leachate, only 15 percent of the nation's landfills are lined and 5 percent incorporate leachate controlling systems; less than 30 percent of landfills are equipped with groundwater monitoring systems. Operators attempt to prevent leaching by capping off the landfill and pumping, but the process is expensive and often only partially successful Alternative methods such as incineration still require September 1990 Page 91 ------- some landfill space and consume large amounts of energy, while recycling can create sludge with high concentrations of hazardous constituents that may eventually leach into groundwater. • On-site septic tank systems are used by about 25 percent of all U.S. housing units; however, only about 30 percent of the nation's soil is suitable for on-site systems, and it is reasonable to assume that some systems are installed in unsuitable sites. Many of these systems are poorly designed or outdated for handling the wide range of chemicals in today's household water. Inadequate permitting and inspection procedures can exacerbate the problem. • Exfiltration from defective or deteriorating sewage collection lines and treatment facilities is increasingly a problem as more and more of the nation's sewer structures approach the end of their useful lives. • Special hazardous waste may add to future water quality problems. Such waste includes post-incineration treatment facilities' sludge ash containing high concentrations of inorganic pollutants, household solid waste containing hazardous materials and some cleaning supplies and paints containing toxic solvent. Improper disposal of such wastes can also threaten water quality. Air Pollution Much of the pollution in the air falls on surface waters and the land, where it eventually infiltrates into groundwater. Other contributors to water pollution include new compounds, which form air- suspended particles that react with other chemicals (acid rain), and improperly incinerated solid waste, which creates toxic organic compounds. Potential to Turn Waste Materials Into Resources Communities sometimes ignore the potential for using waste materials as productive resources, thereby aggravating the pollution problem. The work group highlighted several waste materials that are potentially useful resources including wastewater, sewage nutrients and solid waste. September 1990 page 92 ------- Impediments to Solving Problems Political Increasingly, local governments are relied on not only to legislate improvements to water quality but also to implement, enforce and finance such improvements. In many cases, this responsibility places local authorities in the difficult position of creating and enforcing laws that can cause hardships such as citizen disapproval, industry relocation or job loss for authorities or their constituents. In addition, when the pollution problem crosses boundaries, the local government may need to relinquish its autonomy to the regulatory power of a state or regional authority. Financial EPA estimates that $84 billion will be required to construct treatment and collection facilities and to enlarge, upgrade and replace existing treatment works. The estimate approaches $150 billion when solutions to other problems such as premature wastewater system deterioration, inadequate was- tewater reserve capacity, runoff pollution, combined sewer overflows and stormwater inadequacies are considered. Meeting these needs presents a significant financial burden for society and, more specifically, com- munities. Communities must balance water quality solutions with many other pressing social needs. In addition, many local governments that have used landfills have the additional burden of retroactive liability. With growth and technological advances, communities will face additional expenses for con- struction and maintenance of community water quality facilities. Furthermore, many local communities have no funding mechanisms for coping with such problems as combined sewer overflows and stormwater management. Cultural Part of the overall problem is the public's lack of understanding about the nature of the environ- ment, including its fragility and society's impact on the environment. Furthermore, there is a tendency to focus on the short term—to thoughtlessly consume resources and produce waste. Only an informed minority is aware of the severity of the problems and need for solutions. Federal, state and local govern- ments play an increasingly critical role in environmental education, but the problems must be ad- dressed societywide. September 1990 Page 93 ------- Energy and Resource Extraction Work Group Executive Summary Energy and mineral extraction activities may have a variety of impacts on water quality, many of which are controlled by a large and complex body of regulations and project review procedures. Some adverse impacts on water quality still occur, however, because of past practices, gaps in the existing regulatory system and lack of enforcement. Moreover, existing regulations generally do not address or support energy and mineral resource conservation or the use of alternative energy sources, both of which would contribute toward reducing water quality impacts. The Phase II Report of the Energy and Resource Extraction Work Group identifies water quality im- pacts associated with exploration and production of energy and mineral resources but does not discuss impacts associated with activities further down the production process, such as petroleum refining and mineral smelting. The report notes the potential for energy conservation and efficiency—as well as materials re-use and recycling—to reduce water quality impacts. Scope of the Problems Oil and Gas Industries The location, assessment and recovery of oil and gas resources entails operations that inherently cany the potential for affecting surface water and groundwater resources, as well as species that depend on them. Although the effects of these operations are controlled directly by various federal, state and local regulations and indirectly through environmental review procedures, adverse water quality impacts may still result from oil and gas operations. The report identifies the following problems, which are not yet resolved: • Lower energy prices in recent years have reduced incentives to implement energy conservation technologies to improve efficiency. Technological efficiencies can reduce pressures to develop new energy resources or rely on marginal reserves, thus decreasing the water quality impacts potentially associated with mineral extraction. September 1990 Page 94 ------- Small operations producing oil and gas from marginal reserves often may not be as well maintained and may create greater water quality impacts than large operations. Ineffective facility designs allow stonnwater runoff from oil and gas facilities to collect and transport pollutants to surface or ground waters. Where facilities are inadequate, stonnwater runoff from oil and gas facilities can collect and transfer pollutants. Improper containment and disposal of wastes from oil and gas exploration and production activities may result in contamination of surface and ground waters or the marine environment. A1987 EPA report to Congress documented numerous cases of inadequate containment and improper disposal of drilling and production wastes associated with oil and gas extraction activities. Current regulations, if not adequately enforced, do not adequately control the water quality impacts resulting from disposal of produced waters from oil and gas extraction activities. If improperly managed, oil and gas production wastes may severely contaminate sediments. Improperly closed and abandoned oil and gas wells, which can seriously impact underground sources of drinking water. Spills or leaks from storage tanks can contaminate surface waters, soil, and groundwater. Existing regulations for aboveground storage tanks are inadequate to minimize risks of such contamination. In addition to platform and tanker accidents, discharges or runoff from offshore exploration or production operations can impact quality in marine waters. Coal and Mineral Extraction and Processing Most of the water quality impacts from processing of mining and minerals are problems associated with nonpoint source runoff. Surface waters are contaminated by stonnwater runoff from mining sites, and groundwater is polluted by seepage from waste impoundments and storage areas. Problems occur with direct discharges of wastewater from mining and minerals processing ac- tivities because many states do not apply water quality-based permitting to mining operations. Other problems identified by the report relate to acid mine drainage from coal mines and trace metal pollution September 1990 page 95 ------- from metal mining operations. Coal mining can potentially conflict with wetlands preservation when deposits are located below or near these waterbodies. Impediments to Solving Problems Improvements in energy conservation and efficiency and materials re-use and recycling have the greatest potential to reduce water quality impacts from energy and mineral development Implementa- tion of these practices, however, is often not amenable to regulatory mandates. Furthermore, conserva- tion technologies may not be available or economically practicable. Lack of communication regarding the benefits of conservation measures hinders reorientation of pollution control efforts to incorporate such measures. The need to protect water quality in areas subject to energy or mineral extraction often conflicts with society's need to use energy and mineral resources. The difficulty of choosing how to improve efforts to protect water quality without excessively restricting development of energy or mineral resources is a major impediment to strengthening the existing regulatory system. In general, enforcement efforts are hampered by difficulties in identifying those operations that will potentially cause water quality problems. September 1990 Page 96 ------- Industrial Work Group Executive Summary Despite considerable progress in cleaning up industrial discharges—most notably in controlling conventional pollutants such as oil and grease and suspended solids—many waters in the US. still suf- fer from industrial pollution. Among the many human and natural activities contribute to water pollu- tion, industrial discharges can cause considerable problems in some waterbodies. Toxic wastes have contaminated both ground and surface sources of drinking water, affecting human health and the vitality of many aquatic species and resulting in economic and aesthetic losses. Several impediments hamper effective protection of water quality from industrial pollution: • Institutional limitations, such as lack of sufficient resources at all levels of government; • Inadequate scientific bases for developing criteria and standards; ' Regulatory reliance on technology-based, end-of-pipe effluent controls rather than pollution prevention; • Inadequate public education and inadequate professional training; and • A lack of cohesion and consistency in federal regulatory programs that gives rise to key policy problems with respect to industry and water quality. Scope of the Problems The nation's waters continue to be affected by contaminants from a variety of sources, including sig- nificant contributions from industry, municipal discharges, agriculture and urban runoff. These con- taminants can adversely affect both human health and the integrity of ecosystems. Although there are monitoring gaps in evaluating the impact of discharges on both human health and ecosystems, data from several sources and sites around the country suggest that both ongoing and past industrial activities continue to threaten water quality. For example, in 1988,21 states issued a total of 135 bans on fishing in selected waterways and 39 states reported a total of 586 fishing advisories, restrictions that represented major economic and recreational losses. The pollutants most commonly identified as causing advisories or bans were PCBs, chlordane, mercury, dioxin and DDT. Many wildlife species suffer from the often subtle and long-term impacts of exposure to industrial toxins. Instances of high rates of liver tumors in bottom-dwelling fish such as bullheads and white suck- September 1990 " Page 97 ------- ers have been correlated with the presence of poh/nudear aromatic hydrocarbons, which are found in industrial wastewaters, some of which are carcinogens. Industrial land use practices also stress aquatic ecosystems. Construction and use of industrial com* plexes can create severe watershed impacts such as erosion and sedimentation, higher stonnwater flows in local streams, loss of riparian habitat and, with the loss of natural infiltration, increased loadings of pollutants in stonnwater runoff. In addition, some developers site facilities in wetlands, thus destroying these valuable aquatic resources. Insufficiently treated industrial wastewater discharges are a significant source of adverse ecological effects in U.S. waters. The dean Water Act established a goal of zero discharge by 1985, but it also created a permitting system that allows discharge of pollutants up to certain limits. States have only recently begun to adopt water quality-based standards for toxics and have barely begun to insert water quality-based limits or monitoring requirements for toxics in industrial discharge permits. As a result, there are varying incentives among states for industries to reduce discharges of toxic wastes. In addition, states have focused on the outfall pipe as the source of contamination, and placed less' emphasis on other modes of industrial water pollution such as surface runoff from industrial sites where toxic pollutants are spilled or stored, leachates from landfills and deep well injections that con- taminate groundwater on or off industrial sites, and deposition of airborne industrial emissions. Lastly, scientific research into past industrial practices has identified previously unrecognized residual toxic contaminants that must now be addressed. Impediments to Solving Problems Institutional Implementation of water quality goals has been hampered by a variety of institutional impedi- ments, including lack of resources, lack of a coordinated permitting process for all environmental media and an institutional focus on point sources. The resulting institutional situation impedes development of innovative solutions to industrial pollution problems. Scientific The lack of scientific understanding of the release, fate and transport of contaminants in ecosystems restricts assessment of the impacts of pollutants on ecosystem components. As a result, there is a lack of scientific knowledge upon which to base water quality criteria and standards. Moreover, the absence of effective and inexpensive analytical procedures for monitoring environmental releases contributes fur- ther to this lack of scientific knowledge. September 1990 Page 98 ------- Conventional risk assessment approaches only partially incorporate the full range of impacts to human health and the environment. Many risk assessments focus solely on cancer, even though it is only one of many human health effects caused by waterbome pollutants. Furthermore/ human health is not the only area to consider—effects on ecosystems must also be fully considered in risk assessments. Incorporation of these additional factors is restricted by lack of scientific understanding, which results in impretisions in modeling the fate and transport of contaminants in surface and ground waters. One of the most prevalent factors that clouds the use and interpretation of scientific information is inadequate, conflicting or imprecise data. Generally, there is little or no data on the generation of in- dustrial hazardous waste that is consistent nationally; deficiencies in monitoring programs may also create significant data gaps. As a result, basic information about the relative health or degradation of waters nationwide is unavailable. Technological The historical emphasis on end-of-pipe treatment technologies for industrial water pollution control. has resulted in a focus on control objectives that are specific to a single medium—air, surface water or groundwater—without giving adequate attention to cross-media transfer of contaminants. This focus on treating wastewaters prior to discharge has not of itself, provided a stimulus for preventing pollution before it is generated. The lack of innovative technologies to facilitate adoption of multi-media ap- proaches and pollution prevention is a significant impediment to improving water quality in the U.S. There continue to be impediments to the adoption and expansion of industrial practices that can reduce generation and discharge of wastes and wastewaters. Opportunities for source reduction and recycling are impeded by the lack of adequate technologies as well as by interpretation of regulations by permitting authorities and limited technology transfer, especially between large and small companies. Adoption of best management practices is also hindered by both technological and informational bar- riers. Educational Industry, regulators, scientists, environmental groups, the media and the public are not well-in- formed about most aspects of environmental pollution, in part through gaps in scientific knowledge but also because of inadequate education and training and the difficulty of communicating available infor- mation about complex dynamic issues in easy-to-understand terms without political bias. Consequent- ly, as a nation we have not yet sufficiently institutionalized an environmental ethic that incorporates a concern for human health and healthy ecosystems or the concept of pollution prevention. An additional problem is the shortage of trained professionals in many environmental disciplines. September 1990 Page 99 ------- Policy Problems Related to Industrial Discharges Federal regulatory programs suffer from a lack of cohesion and consistency. Because of the way regulatory and statutory programs have evolved, the method for regulating a pollutant depends on the media to which it is discharged. Differences also exist in requirements for direct and indirect dis- chargers. In addition, the flexibility discretion given states in establishing water quality standards has resulted in uneven water quality protection from state to state and even within individual states. These and other issues, such as the appropriate use of risk assessments, the lack of coordination be- tween land use planning and water quality policies and the need for dedsionmakers to act in the ab- sence of complete scientific information, pose significant challenges for policymakers at all levels of government September 1990 Page 100 ------- Legislation Work Group Executive Summary Since 1960s, the catalog of legislation to restore water quality has grown, as has public concern about water pollution. Recently, legislation has stressed increased regulatory responsibilities for the federal government, attempts to fill gaps left by previous legislation, increasingly explicit requirements for the treatment of toxics, and precisely detailed statutes. However, despite an intensified focus on water quality issues, legislation is often a patchwork with conflicting objectives. The Phase n Report of the Legislation Work Group identified a number of areas where legislation has either created problems or failed to address important issues: • Statutory gaps, overlaps and conflicts; • Inadvertent conflicts and inappropriate incentives or disincentives; • Inadequacies in assessing progress; • Legislative and regulatory impediments to timely action; • Intergovernmental conflicts; • The gap between funding levels and the national mandate for dean water; • Multimedia pollution; and • Control of contaminated runoff. Jurisdictional conflicts in both the legislative and executive branches of the federal government im- pede solution of these water quality problems. Scope of the Problems Protecting Environmental Values Laws related to water quality often have unclear objectives. Competing concerns among environ- mental issues — and between environmental issues and other national priorities — can lead to ineffi- cient overlaps and inconsistencies among the various laws. September 1990 Page 101 ------- • Four categories of environmental values compete for prominence: ecological effects, cancer and non-cancer health risks and welfare effects. Often there is no dear delineation or agreement as to the relative importance of these categories. • Environmental values must compete with other goals such as administrative efficiency, competitive equity among states and industry, economic vitality, private property rights, national security and human health needs. Powerful constituencies battle over the relative importance of each goal which hinders the aggressive pursuit of environmental values. Statutory Gaps, Overlaps and Conflicts Environmental laws do not cover water quality issues efficiently because the complicated commit- tee system in Congress impedes coordination. Since the focus on these issues varies, laws can be need- lessly repetitive in some areas, while leaving gaps in others. • Unclear jurisdiction among congressional committees leads to multiple referrals that can slow passage of a bill. • Legislation often addresses specific constituencies and fails to be comprehensive. For example, there are at least 15 federal statues on water quality. This piecemeal approach can leave important gaps in some regulations, yet create redundancies in other areas. Inadvertent Conflicts and Inappropriate Incentives or Disincentives Legislation not related to water quality can have adverse effects on environmental goals. Examples include changes in the U.S. tax code that inadvertently restrict local governments' ability to use tax-ex- empt financing for water infrastructure needs and farm programs that often conflict with water quality goals. Inadequacies in Measuring Progress Laws often do not require baseline data collection to measure environmental results. Inadequate data can contribute to such program problems as lack of accountability, inadequate oversight and poor focus. Legislative and Regulatory Impediments Statutory deadlines, essential to timely regulatory action, can become so numerous that they exacer- bate an already slow regulatory process. September 1990 Page 102 ------- • When too many deadlines are placed upon federal agencies, the result can be a "triage approach" to programs in which only the most important deadlines are met • Complicated EPA rule-writing procedures, combined with Office of Management and Budget (OMB) clearance requirements, greatly impede the timeliness of the regulation writing process. Intergovernmental Issues Both interstate and interagency issues can be barriers to successful local state and federal partner- ships. • Interstate issues: States have difficulty agreeing on the best way to protect shared waterbodies; they also tend to be less aggressive in abating pollution when there are only downstream impacts. • Interagency issues: Federal agencies have different missions, mandates and priorities. Legislation often fails to define linkages between agencies that are required to work together, making interagency cooperation difficult Funding-Mandate Gap Since 1980, constant dollar funding in the EPA budget for water quality programs has dropped 12 percent. In the future, financial restraints wiH reduce the ability of all levels of government to meet their water quality mandates. Multimedia Pollution Current legislation tends to be focused on identifiable sources of pollution on a media-specific basis. As a result, programs that solve one pollution problem can create others of a cross-media nature. Contaminated Runoff Control Contaminated runoff accounts for an estimated 60 percent of the remaining water quality problems. The types of regulatory mechanisms that work for point source pollution will not be effective in control- ling diffuse sources. September 1990 Page 103 ------- Impediments to Solving Problems Jurisdictional Conflicts Jurisdiction^ conflicts over water quality issues occur in both the legislative and executive branches of the federal government, as well as among state governments. Developing comprehensive and effec- tive water quality programs is difficult when responsibilities are not dearly delineated. • Multiple jurisdictions among congressional committees will continue to prevent a comprehensive approach to water quality legislation. As a result, legislation aimed at new issues is likely to have gaps and overlaps that will prevent effective action. • In the executive branch, there is no dear delineation of responsibilities among the various agencies that have an interest in water quality issues. This makes writing legislation difficult because it is not always dear who should administer new programs. • On the intergovernmental level, water quality laws are not dear as to when federal responsibility ends and state responsibility begins. Similarly, states often cannot agree on the division of responsibility for shared bodies of water. Cumbersome Bureaucratic Procedures Effective regulation writing cannot take place until bureaucratic procedures are streamlined. Cum- bersome internal rule writing at EPA is exacerbated by OMB requirements. Fiscal Restraints Competing national priorities ensure that the budgetary crisis will not ease soon. Legislators will be reluctant to allocate new funds for water quality programs in the face of pressure to cut the budget This period of fiscal tightness comes during a time of demands for increased funding to confront new water quality issues. September 1990 Page 104 ------- Recreation Work Group Executive Summary Participation in outdoor recreation, especially water-based recreation, is an American way of life. Ninety percent of US citizens use the out-of-doors for recreation. In addition, our outdoor recreation sites attract an increasing number of foreign visitors every year. Scope of the Problems The water quality and quantity of this nation's lakes, rivers and streams affects the demand for and supply of these recreational opportunities. On the other hand, since so many people participate in out- door recreation, there can be potentially adverse environmental impacts from these activities, including pollution from both water- and land-based point and nonpoint sources and land use problems. Water-based recreational activity can have an adverse impact on water quality, particularly when activities attract large numbers of participants. Compared to the more widespread effects from most sources of pollution, degradations in water quality that result from recreational activities generally are localized. Such degradation can be significant if it occurs in sensitive and pristine areas. For example, participating in recreational use of rivers has increased to the extent that certain prime river recreation areas have experienced extreme overuse. The UJS. Environmental Protection Agency (EPA) does not have readily available data on water quality trends that can be used to determine the national recreation benefits from its program-induced water quality improvements. Such information would be extremely useful both for assessing progress in reducing and avoiding damage from pollution and for strategic planning at all levels of government. Impediments to Solving Problems Before there can be improvements in both the quality and quantity of water-based recreational resources, impediments to change must be identified. Obstacles, which can be both institutional and political, include the lack of information needed for sound management, inadequate financial resources and insufficient public education about recreation's effect on water quality. Illustrations of both the im- pediments and programs to overcome them are given in sections on the Great Lakes and Chesapeake Bay. In addition, since most decisions about recreational water resources are made by the states and local governments, their dean water strategies are discussed in detail. With a few exceptions, the development of organized and comprehensive water resource manage- ment policies has not been encouraged at the state leveL Therefore, practical and economic sue September 1990 Page 105 ------- have been poorly documented, leaving no foundation for policy development This general lack of data and the poor dissemination of information are major impediments to environmentally sound recrea- tional development Similarly, there is not a comprehensive water resource management policy at the national level Therefore, a national central information system and center for water data that could be used for education and training is of primary importance. Finally, since development of recreational water resources will be impeded by lack of state and federal funding, local communities must be prepared to shoulder the costs of many future projects. September 1990 Page 106 ------- Transportation Work Group Executive Summary Almost every aspect of the transportation sector can affect water quality adversely. In its Phase n Report, this work group identified the most serious impacts from transportation activities and categorized them in the following three areas: • Runoff from transportation facilities; • Spills of harmful substances; and • Impacts from dredging and/or filling. Although not all of these impacts can be eliminated, most can be reduced through greater attention to proper planning, design, construction, maintenance and operation. The term 'transportation facilities" includes all equipment and facilities for moving goods and people, including highways, railroads, airports, pipelines, harbors, cars, waterways, parking lots, trucks, trains, ships and other carriers, as well as the associated storage facilities, maintenance facilities, fuel storage and transfer areas. Scope of the Problems Runoff from transportation facilities degrades water quality. The magnitude of the pollution depends on planning decisions and the design and construction of facilities as well as their operation and maintenance. The actual impact of runoff on water quality depends on such factors as volume, flow (peak rate and total discharge) and constituents. Other environmental characteristics that determine the seriousness of the impact include land use patterns in an area, characteristics of the transportation mode and infrastructure, the geography, geology and plant cover of the drainage basin and the hydraulics, chemistry and biology of the receiving waters. Transportation facilities must be planned, designed and constructed carefully or they will be a threat to water quality, especially if they are built near sensitive waters. Appropriate structures and methods of construction to minimize potential adverse effects, such as best management practices (BMPs) to control runoff, erosion and sedimentation are usually specified in the planning and design stages, but at times they may be neglected as the project advances into construction. Almost all maintenance and operation activities have the potential to harm water quality, such as those related to building yards; storage and dispensing of fuel, oil and antifreeze; and application September 1990 Page 107 ------- methods for maintenance materials. The lack of collection facilities contributes to the problem by im- peding collection of small quantities of by-product materials. Spills and unplanned discharges occur frequently but randomly. Since large quantities of petroleum products and other chemicals are produced, transported and used annually, every community is at some risk. While large spills often capture the attention of the media and the public, smaller spills, often overlooked, may have equally serious cumulative impacts, and most could be prevented. To further complicate the problem, the known principles of spill prevention and mitigation are still not widely understood or adopted at all operational levels, which sometimes results in avoidable spills from equipment failure and human error. Furthermore, research on new mitigation methods has been drastically reduced in recent years. Therefore, response to spills is often inadequate. The dredging and filling issues that have received the greatest attention are • The types and concentration levels of contaminants present in the sediments; • The potential for contaminants to be stirred up or made bioavailable to aquatic organisms; • The short-term and long-term effects of such bioavailability; and • Alternative placement sites and methodologies. Alternative placement sites for dredged material include confined disposal facilities. However, im- proper design and operation of these facilities can result in overflow that carries suspended solids and associated contaminants back to the waterways. Runoff from rainfall on a confined disposal facility can erode dredged material, carrying contaminants to surface waters or leaching them into the groundwater. Relocating "dean" sediment in water environments instead of using it for beneficial uses (beach nourishment, wave attenuation and wetland creation and restoration) may also contribute to short-term water quality problems such as turbidity and interference with aquatic life, and, in addition, fails to take advantage of a valuable resource. Dredging or filling, especially for new facilities, often impacts wetlands. In spite of general support for a goal of no net loss, citizens still have problems with its application, the decisionmaking process, and with understanding terms such as "wetland value/ "mitigation" and "no net loss." Secondary impacts from development stimulated by or made possible by new transportation facilities are usually much greater than those from the facilities themselves. The public seems to favor low-density development, which requires more individual, private transportation. There has been an overall institutional failure to integrate transportation planning and land use planning and to recognize and respond to secondary growth-related water quality impacts. September 1990 Page 108 ------- Impediments to Solving Problems There are many impediments to solving problems created by tansportation activities, including the following: • Lack of collection facilities for used ou, antifreeze and other materials used for transportation maintenance by individuals and small maintenance and repair shops. • Lack of knowledge about how (and how much) individual pollutants and pollutant combinations affect wetlands and their functions. • Inadequate response teams for handling major hazardous material spills. • Inadequate research funds for developing better methods for preventing and controlling spills, especially in the open ocean. • Lack of standards on levels of contamination of sediments that might require special handling. • Lack of sound technical basis for interpreting the ecological significance of contaminant uptake from sediments. • The continued public desire for dispersed, low-density development, which forces reliance on more highways and more travel by individual cars and produces more pollutants than would high-density, planned development served by mass transit September 1990 Page 109 ------- Water Supply Work Group Executive Summary Achieving an adequate, safe, potable water supply is getting more and more difficult as increased pressure is placed on current sources. The Phase n Report of the Water Supply Work Group identifies 12 problem areas that need to be addressed: infrastructure, institutions, technology, water quality, water quantity, sources, small systems, human resources, legal issues, economics, conservation and public education. Scope of the Problems • Infrastructure. The annual investment in capital and operation and maintenance for water supply facilities relative to the total value of plants reflects an on-going disinvestment in the nation's water supply infrastructure. This disinvestment is exacerbated by several factors, including numerous infrastructure needs competing for scarce funds; changes in tax laws restricting funds for capital investment* public undervaluing of drinking water; inadequate distribution systems; decentralized and fragmented water supply industry; and lack of a comprehensive public water systems program. • Institutions. Institutions responsible for water delivery include private corporations, municipal corporations, special utility districts, cooperatives and individual owners. Such fragmentation has inhibited a rational water plan based on watershed or aquifer boundaries. • Technology. Technology development and demonstration in water supply lags behind the need for new, cost-effective methods, procedures and equipment for controlling contaminants. As EPA develops new regulations to protect the public from new contaminants, the gap between available technology and technology needs increases. • Quality. Many communities do not provide an acceptable standard of water service. Some basic causes include inadequate treatment technology; lack of fully established, cost-effective technology for certain contaminants; inadequately protected watersheds; and lack of adequate monitoring of drinking water quality. September 1990 Page 110 ------- Quantity. Many factors have increased pressure on the available quantity of potable water, including population growth, lack of conservation, contamination, legislation precluding developing available sources, inability to resolve competing demands, an inadequate framework for development planning and lack of incentives to maximize efficient use. Sources. Many watersheds, rivers and aquifers are fully committed. Watershed or basinwide planning for water supply is lacking nationally, resulting in inefficient use of water. Small Systems. Community water systems serving less than 3,300 people commit over 90 percent of Safe Drinking Water Act violations. Small system managers, operators, boards and consumers are not well informed about the state and federal regulatory requirements or of the implications of poor quality water supplies. Efforts to upgrade and monitor small systems are also limited by insufficient technical expertise, financial resources and basic management skills. Human Resources. Jobs in the water industry require sophisticated technical and management skills. There is some concern that the work force is not adequately prepared for such highly skilled jobs. Legal Issues. The complexity of the legal environment can inhibit rational detisionmaking by both the private and public sectors, which frequently interferes with attainment of water quality and water supply goals. Economics. Government subsidies have hidden the true cost of providing safe drinking water. Elected officials and regulators are reluctant to raise rates to cover capital costs for small system upgrades that can be prohibitively expensive. Despite the lack of federal assistance for municipal systems, tax incentives do not promote privatization of utilities. Conservation. Conservation attitudes vary across the country. While many citizens desire conservation, they are unwilling to accept higher prices, creating conflicting social values. Public Education. The public is not well informed about water supply issues. For instance, the public is unaware of the true cost of providing potable water; the dose relationships between water supply, water use and water pollution; and the concept that water is a depletable resource that must be used efficiently. September 1990 Page 111 ------- Impediments to Solving Problems Federal and State Technical and Financial Support Federal support of the water industry has been insufficient and has dampened progress in several areas: • Research and demonstration projects to enable technology to keep pace with new regulations; • Centralized and comprehensive approach for contaminant removal; and • Strong enforcement at both the federal and state levels to force technology application. • In addition, small system managers and operators have found it difficult to obtain financial and technical assistance at the state and federal level. Legislative Support. Legislative and judicial bodies support the "not in my back yard" phenomenon, impeding new water supply projects. As tax payers and rate payers continue to resist funding the supply and treatment projects mandated by legislation, cooperation among levels of government is becoming difficult. Political Support In the political arena, water issues have not been high on the agenda. State lawmakers and the public are unclear as to how to handle the tradeoffs between cost, quality and quantity. In addition, without an immediate crisis, it is difficult to generate support for immediate action to deal with future water scarcity problems. Changes in water use or water supply tend to create political turmoil (development that is viewed as environmental degradation; transfer of water rights that creates economic dislocation; interbasin transfers that are viewed as lost future opportunities in own area; and patchwork laws that inhibit movement of water to its highest economic use). In general, political leaders have not accepted strategies for maximizing the existing water supplies, such as conservation methods or rate incentives. Public Education. Attitudes and traditional practices are difficult to change because the current system of water pricing hides the true cost of water use; the public is accustomed to cheap water and not readily accepting of rate increases; and the sense of crisis, necessary for change, has not been reached. In addition, the public does not have a sound understanding of the costs and benefits of conservation. September 1990 Page 112 ------- Industry Fragmentation. The fragmented nature of the water supply industry and the generally small size of systems make it difficult to provide the necessary resources to assure quality. In addition, the water supply industry does not have a sufficient number of qualified employees (engineers, chemists, microbiologists). Fragmentation among states and institutions in water policy and law also inhibit coordinated planning for water development and use. September 1990 Page 113 ------- Watershed Work Group Executive Summary Progress has been made in cleaning up the nation's waters since the passage of the dean Water Act Amendments of 1972, but the quality of our surface water and groundwater is still seriously threatened by a broad range of pollutants and pollution sources. The Phase E Report of the Watershed Work Group identifies a number of issues affecting basinwide water quality management, including fragmented ap- proaches, responsibilities and accountability as well as conflicting laws, the predominance of a local planning focus, the lack of analytical techniques and the incorporation of risk. Scope of the Problems Fragmented Approaches Total pollutant loadings from nonpoint and point sources within a river basin are not adequately addressed by existing pollution control programs, which are inefficient and economically wasteful These piecemeal efforts to address multiple sources result in fragmented approaches to control that fan to reduce pollution and may simply transfer contamination from one medium to another. Examples in- clude incineration of solid waste, which has polluted both air and water, and improper pretreatment of industrial wastewaters entering municipal sewers, which has created a new problem associated with the disposal of contaminated sludge. Fragmented Responsibilities The responsibility for water pollution abatement and control is divided among a number of federal and state agencies and local governments. Moreover, even within individual government agencies and organizations, responsibility for water pollution control programs is frequently divided among several divisions. Therefore, it is difficult to hold any single agency or group of agencies accountable for most water pollution problems. The lack of federal funding and leadership often places these burdens entirely upon local units of government. Within the current system, decisionmakers tend to focus on local pollution concerns that, in many cases, may be of lower priority than regional concerns. Moreover, solutions devised to address only local water pollution concerns are a fragmented approach that cannot effectively protect water resources. September 1990 Page ------- Fragmented Accountability Measures of success that are currently being used to evaluate progress toward meeting pollution abatement goals and objectives may not be appropriate; in fact, many are not reflective of the basic tenets of the dean Water Act. For example, accountability systems currently used by the Environmental Protection Agency (EPA) to evaluate and redirect water pollution control programs are oriented toward bureaucratically derived measures of success rather than true measures of environmental results. It is of little value to measure program success on the number of discharge permits if issuance of those permits has little impact on the overall improvement of water quality or protection of living resources within a watershed. Conflicting Laws Conflicting laws and programs that are inconsistent with national environmental goals and objec- tives are also problems that undermine federal state and local governments' ability to protect water quality. In this time of declining federal funds, many environmental laws are not adequately imple- mented by water quality agencies to protect watersheds expediently and cost-effectively by noting and attacking priority problems first and preventing future problems. Local Focus Recent federal policy places the burden for planning and executing pollution controls at the state and local level but has not established clear accountability or responsibility for those programs. Fre- quently, the responsibility is not matched by the financial resources or political independence necessary to accomplish the job. For example, the federal grant program funding construction of municipal sewage treatment plants is being phased out. It has been replaced with a program that encourages financing of plant construction through state revolving loan funds. Establishment of these funds has posed some difficult political and financial questions for both state and local governments. Problems can be anticipated in implementing any new program or approach to pollution control; however, cur- rent national management systems may not be flexible enough to respond to them. Lack of Analytical Techniques An additional problem confronting federal and state water pollution control agencies is the slow pace in developing and using new scientific techniques to address broad water pollution problems. The less flexibility we have to focus on broad and complex priority problems, the more planning suffers be- cause local peculiarities cannot be factored in. When new methodologies are not employed and problems are not approached on a watershed basis, it is difficult to determine not only impacts but also sources of pollution. September 1990 Page 115 ------- Incorporation of Risk The current approach to water quality management exercised by EPA through its various program offices should be revised to comprehensively address priority issues that focus on environmental as well as human risks. Existing environmental programs generally focus on specific media such as air or water and not on geographic regions. This does not make scientific or programmatic sense from a watershed perspective and exacerbates the fragmentation of efforts, making it extremely difficult to clearly define priorities, develop integrated solutions to pollution problems and carefully cany out comprehensive strategic planning. Impediments to Solving Problems The previously addressed problems resulted from the lack of a holistic watershed approach to basinwide water quality management These issues can be characterized by the following deficiencies: • A fragmented approach to planning and management; • The lack of cumulative impact analysis on a watershed basis; • The lack of strategic planning; • Lack of connection between data collection and dedsionmaking; and • The lack of attention given to public outreach, education and public involvement. Fragmented Approach to Planning and Management There are several layers of governmental responsibility that are often accompanied by an additional layer of regional authorities. Because these political jurisdictions usually do not coincide with water- shed boundaries, there are often conflicting management decisions. Clearly, there is a need for a nation- al coordinating institution that would provide necessary connection and communication between the layers of government Lack of Cumulative Impact Analysis on a Watershed Basis The majority of controls in point source permits are primarily based on achieving a certain con- centration in the water at a specific site instead of using a total pollutant loading analysis for the tributary, river, or downstream lake or estuary. Downstream concentration or uses to be protected are not considered and bioaccumulation of pollutants has not received the attention that it deserves. September 1990 Page 116 ------- Lack of Strategic Planning Environmental regulators axe often unable to anticipate present and future problems. Requirements of laws have focused institutions' concentration on point source reduction rather than overall preven- tion that would include waste recycling, nonpoint source reduction and general waste control programs. Lack of Connection Between Data Collection and Decisionmaking Institutions fail to use existing information and regularly call for more studies or plans before making a decision that will result in action. In addition, data collection is not always timely and often does not include the information needed for effective environmental management dedsionmaking. Lack of Attention Given to Public Outreach, Education and Public Involvement Environmental education curricula should be developed for all levels of education. An informed public can provide the impetus for governmental action on water quality problems. For example, in the Chesapeake Bay area, public involvement has not only forced government to take action on both nutrient reduction and living resource restoration but also has carried the momentum between political administrations. September 1990 Page ------- APPENDIX G Major Milestones in Federal Water Quality Legislation SURFACE WATER 1899 Rivera and Hubon Act Water Pollution Control Act Federal Water Pollution Control Act Federal Water Pollution Control Act Amend Water Quality Act Federal Water Pollution Control Act Amaodmenu dean Water Act Prohibited discharge of refuse into waterways that would interfere with navigation without a permit from the U.S. Army Corps of Engineers 1948 Provided limited federal financial assistance to local governments for construction of municipal wastewater treatment facilities 1956 Increased federal financial assistance for municipal wastewater treatment facilities 1961 Increased federal financial assistance for municipal wastewater treatment facilities 1965 Required states to develop state water quality standards for interstate waters, and created the Federal Water Pollution Control Administration to establish broad guidelines and approve stale standards Increased federal financial assistance for municipal wastewater treatment facilities 1972 Greatly increased federal financial assistance for municipal wastewater treatment facilities Instituted uniform technology-based effluent limitations for industrial dischargers and a national permit system for all point source dischargers Designated the U.S. Army Corps of Engineers as the permitting authority over discharge of dredged or fill material into U.S. waters 1977 Encouraged states to accept delegation of the national permit system and assume management of the construction grants progiam Added control of priority toxic pollutants to the federal program Municipal Waatewater TVeaunent Construction Orant Amendments Food Security Act Water Quality Act 1981 Reduced federal financial assistance for municipal wastewater treatment facilities 1985 Established erosion control programs for agricultural lands 1987 Phased out federal grants for construction of municipal wastewater treatment facilities; provided capitalization grants to state revolving funds Required EPA to develop regulations for stormwater runoff control Required states to prepare non-point source management programs September 1990 Page 118 ------- Major Milestones in Federal Water Quality Legislation DRINKING WATER Sato Drinking Water Act 1974 Safe Drinking WIRY Act 1986 Amendment! Required EPA to establish national drinking water standards and regulations tat state underground injection control programs Required EPA to establish drinking water standards for additional contaminants Required states to establish wellhead protection programs to protect iground drinking water sources front contamination MARINE WAIflftS Federal Water Foliation Control Act, Act Marine Protection. 1972 Research and Sanctuaries Act National Ocean Pollution 1978 Planning Act Water Quality Act 1961 Redefined interstate waters to include coastal waters 1972 Provided federal grants to coastal slates for developing and implementing state coastal zone management programs and plans Provided federal grants for state acquisition of estuarine sanctuaries Established a system to regulate dumping of materials into die oceans Authorized federal designation of marine sanctuaries through National Oceanographic and Atmospheric Administration (NOAA). Required NOAA to establish a comprehensive ocean pollution research and development and monitoring program 1987 Created the National Estuary Program to develop die-specific management plans for significant estuaries WETLANDS Migratory Bird Hunting 1934 Stamp Act Federal Water Pollution 1972 Control Act Amendments Food Security Act 1985 Emergency Wetlands 1986 Resources Act Authorized the sale of duck stamps to hunters to help fund federal acquisition of waterfowl habitat, primarily wetlands Required permits for discharge of dredged or fin material into U.S. waters, including wetlands Denied federal farm benefits to farmers harvesting an annual crop on converted wetlands Increased federal funding for wetlands acquisition and conservation September 1990 Page 119 ------- |