Recently joining the WEF staff a few years removed from my former EPA life, I was cheered by the new Administration’s focus on sound science, clearly stated by EPA Administrator Lisa Jackson:
“Science must be the backbone for EPA programs. The public health and environmental laws that Congress has enacted depend on rigorous adherence to the best available science.”
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WEF has long supported the National Water Quality Assessment (NAWQA) Program administered by USGS in cooperation with many others. NAWQA is a well-designed and implemented water quality monitoring program producing both national and State/local data and results helpful to informing water management decisions. WEF, in cooperation with USGS, has sponsored a continuing series of congressional briefings to make sure NAWQA findings are understood and discussed by national leaders. The next congressional briefing, which as always is open free to the public, will discuss new findings about the quality of our nation’s private drinking water wells. “The Quality of Our Nation’s Private Drinking Water Wells: Are Current Contaminant Levels Above Public Health Benchmarks?” is scheduled for Friday, March 27 from 9:30-11:30 a.m. in the Cannon Caucus Room of the Cannon House Office Building in Washington, DC. No RSVP is required for attendance. For more information, contact Donna Myers (dnmyers@usgs.gov, 703-648-5012) at USGS or Nick Bardis (nbardis@wef.org, 703-684-2400 x7731) at WEF.
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NAWQA and WWMD are just two examples of how WEF is supporting and advancing water quality monitoring. It’s important that all water professionals work together to help develop the best possible monitoring data to support sound science even as we go full-speed-ahead on watershed management actions.
Water monitoring based on science?
ReplyDeleteMost such data is impressive, but how valid are they?
Here are some of my comments on a recent watershed TMDL study, dealing with some of the essential testing performed.
BOD test: Since it still is common to use its 5-day reading only, one still does not know if this value represents C-BOD5 or N-BOD5. Being a biological test, it is also very important what type of seed (bacteria) is used for the test, as bacteria first have to become acclimated (selective growth of bacteria with the right enzymes) to the waste. If seed is used not yet acclimated these BOD test values are again worthless and can be very misleading.
Ammonia test: Ammonia in the nature's nitrogen cycle represents only a temporary value, since organic nitrogen (urea and proteins) hydrolyzes into ammonia, where it is oxidized into nitrates. Only looking at ammonia is incorrect and misleading.
TDS: most of these tests are taken by comparing its value with its electrical conductivity. If not specifically specified this is the value used by most laboratories, but it solely represents the mineral content of the sample and not the organic solids. This while organic matter is important for any ecological study, which I assume the intent of these studies are.
TSS: Since the test only measures solids larger than 1 micron, this value again is arbitrary and does not mean anything, especially in light of the fact that any natural recycling process depends on the hydrolysis (breaking down of matter into molecules) of matter, most much smaller than 1 micron.
My main objection of any TMDL study is that such studies clearly justify what is a violation of the Clean Water Act, since the Act was meant to be a technology-based (demanding best sewage treatment) and not water-quality-based (setting treatment standards based on the water quality of receiving water bodies), an issue specifically addressed in the Act by Congress, as the later could easily be manipulated by local politicians.
From a common sense point of view, I question the validity of these TMDL studies, as most non-point sources, may have a lot of specific test data (for the Jordan River, about twelve, as I remember), while there is no hard actual flow quantity date, hence makes it a shot in the dark what the TMDL really is. This, while the flow quantities from point sources is well documented, but only with very limited test (BOD5, TSS and pH) data, again showing on paper a lot of data, while most of it is useless.
Although I realize that admitting to past mistakes is very difficult, one would hope that with the future of our environment at stake, common sense will prevail and Utah will take the necessary action to correct what went wrong in the past and initiate programs that really will adhere to the Clean Water Act and protect the public health of the general public. (www.petermaier.net)