CHAPTER
22
Combatting Ignorance About U.S. Water Quality
Gaps in basic information about water quality hobble attempts at all levels of government to improve the quality of our nation’s water resources. Mr. President, a National Water Quality Monitoring Strategy, developed under your leadership and supported by changes to the Clean Water Act, can close these gaps and make possible more efficient and effective water quality management. Tracking national trends in water quality conditions requires a new multiagency effort. This effort must be authorized under the Clean Water Act and be appropriately funded. We recommend that, using amendments to the Clean Water Act, you seek authorization to increase appropriations by 10 percent per year over the next 10 years to support the states’ responsibility for water quality assessment and management in their rivers, lakes, and estuaries. Additionally, we recommend that you initiate an interagency cooperative investment program for the research and development of new technologies to improve the quality and affordability of ambient water monitoring.
The Nation’s Water Quality
Most Americans would be surprised to learn how little we know about the nation’s water quality. For the nation as a whole, and in most areas, we do not know if water quality standards are being met or whether our water quality management programs are yielding improvements. When we find problems or improvements, we rarely have the data to explain the underlying causes. This knowledge gap is unacceptable.
The American public ranks water quality protection among its highest environmental priorities, and as a nation, we spend billions of dollars every year on the improvement of water conditions. Yet we are unable to reliably characterize the condition of many rivers, lakes, and estuaries. Numerous water protection programs have been put in place, but our major water quality statute is 32 years old.
Our ignorance comes at a cost. Serious undetected water quality problems may exist. Equally important, once problems are detected, limited information makes it impossible for localities, states, and federal authorities to identify the most cost-effective response. Then, when action is taken to address a water quality problem, we are unable to judge the policy or investment’s performance. When it comes to the nation’s waters, the highest unmet priorities are identification of the biggest problems and the ability to measure success and failure.
When it comes to the nation’s waters, the highest unmet priorities are identification of the biggest problems and the ability to measure success and failure.
The reason so little is known about water quality conditions is that we are embarking on a new era in water science and regulation. The national approach to water quality management in particular is undergoing a profound shift. In the first 32 years of the Clean Water Act (CWA), attention focused on limiting releases from industrial, commercial, and municipal point sources. Specifically, attention focused on writing, implementing, and enforcing a series of regulations requiring point sources to install mandated pollution control technologies. When the focus was on limiting and monitoring the releases from these point sources, little attention was given to the overall condition of lakes, rivers, and estuaries. Although significant reductions in many pollutants from point sources have been achieved, now the focus is shifting to the condition of waters themselves and the entire range of pollution sources, including agricultural and urban runoff. At the heart of this shift is the so-called Total Maximum Daily Load (TMDL) program. A long-neglected aspect of the CWA, TMDL provisions require states to identify waters that are not in compliance with water quality standards, establish priorities, and implement improvements—including improvements that rely on nonpointsource reductions. This process places a premium on credible water quality information.
The TMDL process has taken center stage because of widespread suspicions that significant water quality problems remain. Where surveys are conducted, often with reliance on very limited data, states report that about one-third of stream miles and 40 percent of the area of lakes and estuaries may not be meeting water quality standards. Put differently, states report that 300,000 miles of river and 5 million acres of lakes are not clean enough to support swimming, fishing, or boating. The National Water-Quality Assessment (NAWQA) program of the U.S. Geological Survey (USGS), while not intended to be a comprehensive national monitoring network, reports that 20 percent of groundwater samples collected exceed drinking-water standards for nitrate concentration, 80 percent of streams sampled have concentrations of phosphorus greater than EPA goals for preventing nuisance plant growth, and pesticides are detectable in 95 percent of groundwater samples. Regulatory and investment needs for the TMDL program demand more intensive attention to localized areas where water quality problems are suspected. Currently, each state targets its monitoring programs differently in light of its own needs, and few can afford a reliable statewide sampling program. Accordingly, available monitoring data tend to not be representative of statewide conditions. When aggregated to the national level, current data are unlikely to be representative of nationwide conditions.
The limited quantity and reliability of water quality information has been recognized by, among others, the states, public utilities, industry, environmental groups, the General Accounting Office, and the National Research Council. According to the 2000 National Water Quality Inventory, two-thirds of the nation’s water bodies are unassessed, meaning that sufficient data do not exist to evaluate water quality conditions in many areas. This year, the director of the Environmental Protection Agency’s Water Office argued that “we are flying blind” when it comes to water quality data. Improving information about water quality conditions requires a monitoring program to collect enough reliable data, basic scientific understanding of how watersheds work, and the advancement of analytical capabilities necessary for interpretation of these data. Federal leadership to improve our national water quality information is both necessary and appropriate. The focused development of modern data collection methods and analytical tools for data analysis is an activity that serves all states and localities. Basic science research to understand how watersheds work will serve all states and localities. The collection and analysis of data on interstate rivers is a logical federal responsibility. A federal water quality information initiative will allow you to demonstrate your commitment to progress on an issue that plagues our environmental programs at all levels of government. It is a broad initiative that requires and is worthy of a president’s attention.
Benefits and Challenges
Improved water quality information will prove valuable for several reasons. First, it will reduce the chance that significant problems are overlooked until we are surprised by human health or ecological injuries. An example of this is the so-called Gulf hypoxia problem. In the last decade, ocean scientists discovered and documented a vast expanse of water in the Gulf of Mexico with reduced oxygen levels, thought to be due in large part to agricultural runoff from the Mississippi, Missouri, and Ohio River basins. More comprehensive monitoring will allow such problems to be detected earlier. In turn, this will help minimize the ecological and economic impact of water quality degradation.
The economic value of better information should not be ignored. Water quality problems can affect large investments made by both the public and private sectors. The success of land development decisions, public infrastructure projects, and industrial production can depend on water quality conditions. Water quality problems can trigger legal issues that force limitations on investment, development, or production. In other cases, businesses rely directly on the availability of clean water. This is true of many industrial facilities, agricultural operations, and recreational service providers. When information on water quality is poor, investments are made on the basis of that poor information. As any investment analyst will tell you, bad information can lead to bad decisions and poor economic outcomes. Toward that end, a central goal of better information is the ability to manage for performance. Monitoring systems should be designed explicitly to deliver information that will allow localities, states, and the nation to experiment with—and judge the performance of—different approaches to water quality improvement. Public sector expenditures, such as agricultural conservation payments, and private sector costs, such as the costs of controlling pollution, can be lowered if we are better informed about what expenditures provide the biggest environmental benefit.
The economic value of better information should not be ignored. Water quality problems can affect large investments made by both the public and private sectors.
Second, improved information will improve the quality of regulation. U.S. water quality regulation already is moving toward watershed-based, ambient regulation. Improved information will vastly improve the quality of this regulation. The maxim that “what gets measured gets managed” should be amended to say that we “regulate even when we do not measure.” Our current inability to measure the performance of private or public actions to improve water quality means that we may be wasting money on policies that have little benefit. Also, our inability to measure makes innovative approaches to regulation impractical. Group discharge permits and water quality trading, by allowing flexibility, could help reduce the costs of achieving water quality improvements. These policy innovations are not possible, however, until environmental performance is reliably measured. Similarly, better information will significantly increase the environmental improvements we get from farm program expenditures dedicated to conservation. When performance can be measured, performance can be demanded.
Third, better information lowers the cost of conflict. Waters are shared by a wide variety of public interests, including agriculture, commercial businesses, municipalities, and recreational enthusiasts. This means that water management decisions and policies often generate social conflict. And conflict is costly. A recent controversy involving the Missouri River is illustrative; here commercial interests seeking the ability to navigate large vessels up the river are pitted against outdoor groups and service industries that want enhanced habitat and water quality. Poor information exacerbates such conflicts. Better information will reduce uncertainty and enhance the credibility of analysis aimed at balancing competing social interests.
Poor information exacerbates conflicts. Better information will reduce uncertainty and enhance the credibility of analysis aimed at balancing competing social interests.
Responsibility for monitoring currently is shared across all levels of government. We believe that a federal leadership role in promoting a strategic approach to water quality information is needed, but this is hampered by law and budgetary circumstances. A challenge will be to settle on the monitoring and assessment responsibilities of each level of government. Stronger federal leadership in the provision of water quality information does not imply a change in responsibility for planning and executing water quality management programs. States and local governments will retain their core responsibilities in the regulation and management of water quality.
Finally, monitoring data—even if improved substantially—cannot describe the condition of any river, lake, or estuary with absolute certainty, especially in consideration of the reality of resource limitations that limit sampling scope and intensity. As a result, the design of a national monitoring strategy should accommodate and include communication strategies to report unavoidable margins of error. Ways to communicate margins of error to the public and to incorporate the reality of this error into decisionmaking must be part of the national water quality information system.
Recommendations
We propose that you appoint a multiagency intergovernmental task force on water quality monitoring. This immediate effort, on a six-month time line, should document the extent, scope, and consequences of current water quality information gaps and set priorities for the most important data needed to fill those gaps. This initial gap analysis is properly led by EPA but should emphasize cooperation and input from the full range of agencies and levels of government.
You should ask the task force to explicitly provide you with recommendations that address funding and the proper division of federal and state responsibilities. Funding for a national monitoring program must be steady and sustainable over the long term. Money is wasted when monitoring systems are put in place and then starved of future funding. Today’s information gaps are due to limited funding levels and a lack of legislative clarity on the purposes to be served by monitoring programs.
Funding for a national monitoring program must be steady and sustainable. Money is wasted when monitoring systems are put in place and then starved of future funding.
We make several specific recommendations. First, you should ask the task force to propose amendments to the CWA to authorize a national program to assess water quality conditions and trends and track them consistently over time. The demand for national scale assessment information is principally a federal responsibility, although a national program cannot be developed or implemented without the support of the states. Appropriations for this program should be $30 million per year, increase over time, and be in addition to existing monitoring funds now available to the agencies. Leadership should be by EPA, but a strong partnership must be fostered with the monitoring programs of other federal agencies, in particular the USGS.
Second, you should ask the task force to propose amendments to the CWA to increase appropriations to support state responsibilities for water quality assessment and management in their rivers, lakes, and estuaries. Funds should increase federal support for state monitoring programs by 10 percent per year for 10 years. Appropriations should be made as grants to the states based on a formula considering population, stream miles and lake and estuarine acres, and state cost-share offers. The task force should explore ways in which the federal government could support state efforts to place fees on water discharge permit holders, dedicated to meeting the cost-sharing requirements of a new federal monitoring grants program. Existing funds also should be deployed in the most cost-effective ways. For example, opportunities to shift monitoring locations and protocols on regulated sources to support watershed scale assessment should be identified. This might be done as part of EPA’s oversight of the National Pollutant Discharge Elimination System (NPDES) program.
Finally, we suggest that the task force give you recommendations for a new federal interagency cooperative R&D investment program—including the National Science Foundation (NSF), EPA, NASA, and USGS—for the development of new technologies to improve the quality and affordability of ambient water monitoring. Monitoring costs are due primarily to the costs of data collection and transmission. Emerging technologies that feature rapid advances in remote sensing, continuous monitoring instruments, and real-time data transmission methods promise to significantly reduce these costs. Unmanned, continuous monitoring with automated data export is already a reality for some water quality measurements and can play a key role in a lower-cost, comprehensive monitoring system. But R&D in this area is not coordinated or funded in a strategic manner. A federal R&D strategy is justified by economies of scale in monitoring research and technology transfer. Also, EPA should be instructed to standardize the procedures by which monitoring technologies are certified. This will enhance the rewards to innovation and promote the timely introduction of superior technologies.
J.B.
L.S.