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Topic 2: Managing Pollutants from Nutrients

2010 March 16

Excess nutrients like nitrogen and phosphorous entering the nations waters create pollution that is hard to track, contain, and control. Nutrient pollution is as damaging to our waters as it is complex, so finding effective ways to address it is critical. EPA and State agencies have used various approaches to tackle the problem but much more is needed to protect water bodies from these pollutants.

•    What critical elements need to be included in an effective nutrient strategy?

•    How should the strategies differ for protecting healthy and functioning watersheds versus those that need to be significantly restored due to previous pollution?

•    What has worked for your organization, state, or tribe in controlling nutrient pollution? What hasn’t?

For more detail about why and how conference participants will be approaching this topic, please see the Discussion Document at right.

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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75 Responses
  1. March 27, 2010

    This is to respond to David Dow’s March 25 comment that stresses the need to move from septic systems to wastewater treatment plants to alleviate nutrient pollution. Dow also mentions emerging contaminants of concern (COCs) that have been identified in the treated effluent. He fails to point out, however, that sewage pollutants removed by wastewater treatment plants, primarily concentrate, not in the effluent, but in the resulting sludge.

    Typical sewage from industrialized urban centers that enters sewage treatment plants contains not only pathogens from human waste, but tens of thousands of industrial chemicals, some of which are highly toxic and persistent. Current regulations permit every industry, institution and business, every month, to discharge 33 pounds of hazardous waste into sewage treatment plants. The regulations governing the land application of sewage sludge test and have standards for only nine toxic metals. For most of the the other industrial sludge chemicals, there are little toxicological data, especially not when these are mixed and interact with other contaminants and then spread on farms as “fertilizer.”
    Is there really any point in EPA and communities spending billions to sewer communities and up-grade sewage treatment plants–which means more and dirtier sludge– only to then permit sludge, which contains most of the removed pollutants, to be returned to the environment where they are degrading ground water and farmland, and making people and animals sick?

    The current regulations permit hundreds of tons of sludge and sludge mixtures to be deposited in spent sand and gravel pits, under the guise of “reclamation” and “soil manufacturing.” In the Northeast these sites are located above stratified drift aquifers, only a few feet away from the water table. There is no groundwater monitoring requirement. When water is tested at these sites–usually only after people complain or get sick–data almost always indicate that the culprit is sludge.

    Eighty-four health, farm, and environmental groups, including the Sierra Club, oppose using sludges as “fertilizer” and have urged EPA to choose alternative sludge disposal options that do not pollute water and degrade the land where we grow our food.

    Here is the link to the Sierra Club policy:

  2. March 26, 2010

    Another important aspect of nutrients and their relationship to water quality needs to be kept in mind in some watersheds. Some pollutants act to reduce the availability of essential nutrients (e.g. metals that are Ca utilization inhibitors can exacerbate the problem of anthropogenically reduced calcium by increasing peristalsis and reducing ability of salmon to obtain prey… thereby harming growth, health, and fitness of salmon smolt to survive when they move out into the marine environment). The salmon, then, do not return to provide marine-derived nutrient to fertilize the watershed to the degree that salmon had evolutionarily adapted to prehistorically. Coho salmon smolt size has been getting smaller and smaller across the range of the salmon, making them less fit to compete in the marine environment. In this important case, metals may be reducing nutrient that had been essential. While salmon, lamprey, and river mussels continue to decline, we avoid pointed investigation of these relationships… and continue to allow adding huge tonnages of lost lead fishing sinkers, boat anchors, and bullets, to low-calcium waters that grind them up in hydrologically active ‘mortar and pestle’ riverine potholes. Lead colloid and larger particulate can end up dissolving in fish gill and gut to directly dose fish and reduce fitness to survive in the ocean. Huge quantities of toxic metal paint flakes, from degrading railroad bridges, ‘feed’ salmon when they fall into the river resembling fishing lures. 303d lists do not relate to any of this. No agency responsible for water quality assessment has done adequate investigation, yet, many millions of dollars are readily spent on culvert replacements to increase fish passage to increase fish rearing habitat…. without adequate assessment to see whether or not the galvanization is poisoning the species of interest in the associated cool water refuge areas that are subject to anthropogenic acidification pressure increases locally. What’s up with that?

  3. March 26, 2010

    I live and work in an area that has a large number of large dairy farms. I remember 15-20 years ago, before the advent of CAFO regulations and focused efforts by the farms to manage nutrient loss. Farm odor and run off losses were significantly greater than they are today. Technological advances, farmer and consultive nutrient planning and management, adequate regulatory oversight along with the farm communities desire to be good environmental citizens have all contributed to this success.

    We are not perfect but progress is being made every day. The next opportunity would seem to be to insure that all farms (large and small animal farms as well as non-animal based crop farms) acurately manage all farm imputs to insure minimal nutrient losses.

  4. March 26, 2010

    The Massachusetts Dept. of Environmental Protection has issued Total Maximum Daily Load requirements to the towns on Cape Cod to upgrade their wastewater infrastructure from septic systems in order to reduce nitrogen loading to our coastal embayments in order to improve water quality and restore key habitats, such as eelgrass beds. To meet this challenge towns like Chatham have decided to sewer the whole town and build a centralized sewage treatment plant, while Mashpee has opted for 25-30 community cluster systems to address this problem. Other towns are in the process of developing their Comprehensive Wastewater Management Plans (CWMP) which have to be approved by Ma. DEP in order to address this challenge. Since it will cost 2-3 billion dollars to upgrade our wastewater infrastructure for the 15 towns on Cape Cod, citizens in each town will need to decide what they are willing to pay to achieve the desired outcomes from this upgrade of our wastewater infrastructure.

    Having worked on the EPA-led Waquoit Bay Watershed Ecological Risk Assessment which focused on nutrients as the major human stressor in the watershed (nitrogen in coastal embayments and phosphorus in freshwater ponds), I have concerns that the focus of the town CWMPs is too narrow. For Waquoit Bay the TMDL targets would require over 90% removal of the nitrogen load by the towns of Mashpee and Falmouth that currently comes from our septic systems. The atmospheric loading of nitrogen to the Waquoit Bay Watershed has been exempted from the TMDL load reductions because it is viewed as not being under local control. Some of the subwatershed components of the Waquoit Bay Watershed have lower TMDL nitrogen reduction targets. The practical problem that we face is what combination of wastewater infrastructure upgrades need to be implemented along with reduced use of fertilizers on lawns and restoration of wetlands/planting more trees in town conservation lands to meet the TMDL targets in a cost effective fashion. An associated issue is that the sediments in Waquoit Bay are in bad shape with a buildup of organic matter and high nutrient concentrations, so that restoration of eelgrass beds is likely to require more than simply meeting the TMDL targets to improve water transparency in the bay. Periodic dieoffs of the macroalgae that have replaced the eelgrass causes fish kills in the bay during the Summer.

    The other issue being raised is that since we have to upgrade our wastewater infrastructure whether we should address emerging contaminants of concern (endocrine disrupters, pharmaceuticals and personal care products, household cleaning products, etc.) at the same time. These COCs have been detected in our groundwater/surface water by investigations conducted by the Silent Spring Institute’s for their Cape Cod Breast Cancer and Environment Study. Some of the advanced centralized sewage treatment approaches to remove nitrogen also reduce the COC levels and the “nitrex” community cluster system proponents claim similar reductions for their system. Ma. DEP has no regulations for removal of these COCs in either wastewater treatment or water treatment for public water supplies. Ma. DEP is looking to EPA to provide guidance and regulations for these COCs.

    From the Sierra Club’s perspective, we need to address the nutrient loading/COC treatment issue in a more integrated fashion than the CWMP’s being developed by each town. Building a new wastewater infrastructure to replace septic system will require the use of a lot of energy and in order to reduce greenhouse gas emissions, we will have to develop the wind energy off of our coast. Sewering portions or the whole town and constructing new centralized sewage treatment plants with discharge of treated effluent back into our sole source aquifer for drinking water will create plumes of low levels of COCs. These COC plumes may need to be addressed by our public water supply systems before drinking water is sent out to the public. Our sandy soil with low levels of organic carbon have limited natural attenuation abilities, so that the treated sewage effluent will quickly move into our groundwater and from their to our surface waters. The sludge from this treatment process will contain adsorbed COCs which will generate a municipal solid waste (MSW) challenge if this sludge is to be converted to a value added product or the organic msw is composted. Thus an integrated response needs to address renewable energy; public water supplies; wastewater treatment and municipal solid wastes.

    It would be useful if EPA’s Coming Together for Clean Water dialog could provide guidance for such an integrated approach, since I am sure that Cape Cod is not the only region in America facing these wastewater infrastructure upgrade challenges. We are already being impacted by climate change (natural environment and socioeconomic system), so that we need to find a way to make the transition to sustainability.

  5. March 25, 2010

    If the EPA is really serious about nutrients in our open waters, it should stop using our open waters as giant urinals and address the water pollution caused by nitrogenous (urine and protein) waste in municipal sewage. This waste besides exerting an oxygen demand is also a fertilizer for algae and therefore contributes to eutrophication, resulting in dead zones.
    EPA ignored this waste, because it used an essential test incorrectly and although it did acknowledge this in 1984, it never corrected this test, while by administrative rule officially not only ignored this waste, but changed the goal of the Clean Water Act from demanding 100% treatment by 1985 (elimination of all pollution) to a measly 35% treatment, thereby apparently considering rivers used as urinals to be swimmable.
    All this, while it still is impossible to evaluate the real treatment efficiencies of sewage treatment plants and what their effluent waste loadings are on receiving water bodies. Correcting this test should and would be a giant step in the right direction to correct many of the mistakes made in the past and fulfill another requirement in the CWA, by establishing best available treatment (95-98%), which with EPA’s own data would actually cost less than the odor control facilities now built.

  6. March 25, 2010

    I own a 91 acre apple farm in the tri-city area of Schenectady, Albany, and Troy, New York, Town of Clifton Park, where water resources are very crucial. During the last 40 years our town has grown by leaps and bounds until we have a population of over 35,000.

    On my farm I am very aware of non-point source pollution and already do everything I can to protect the water in my neighborhood. On my farm I have implemented New York State DEC best management practices including IPM for spraying apple trees along with best practices in order to keep spray drift at an absolute minimum as well as pesticide run off into water sources.

    I think that retaining my farm, and in spite of these necessary farm practices, has actually assisted in keeping cleaner water quality for my community than would have occurred had my land been built out for development. Housing could have, and probably would have, polluted the water much more than my current farming practices.

    I am confident that government will look at the much broader picture of agriculture and would realize that open space, local food sources, and an abundance of food is crucial to the general population, and that local farms actually help the environment, water included. Pressure from mandates and expensive implementation measures would hurt farming and therefore the entire population of the U.S. What we need instead is support for keeping our farms in existence for the good of all.

  7. March 25, 2010

    I have been in dairy practice for 30 years, and have seen farmers become BETTER stewards of the land, year after year. Farmers are using targeted fertilization and weed controll, and using less every year.
    This is in part due to cost/profit. Farmers at this point need have stable EPA regualtions, and at this point, they are stringent enough.
    From here on , the EPA should be simply monitoring for accidents.

  8. March 25, 2010

    The EPA should require states in the Mississippi basin to develop and enforce nutrient standards to reverse the dead zone in the Gulf of Mexico. Non-point nutrient pollution must be stopped by enforcement of existing TDML’s and development of TDML’s for nutrient impaired waterways.

  9. March 25, 2010

    Louisiana is working on the state’s Nutrient Reduction Strategy which should bring many of the necessary partners together to discuss what is possible in reducing nitrogen and phosphorus levels entering inland and coastal waters. We have been involved in the Gulf of Mexico Program for many years and have also been working on nutrient reduction through the Hypoxia initiatives for the Mississippi River.

    Finding the balance of what is understood and can be implemented now and what areas still need additional research to help improve watershed and instream models will continue to be important for this work to move forward and result in progress. Industry and agriculture will remain involved if they feel that science and information are the basis for the decisions and people are willing to accept what can reasonably be accomplished in coastal systems.

    New and innovative technologies are available and some of the industries and municipalities are utlizing them but others are concernced about the costs and effectiveness and fear further regulations beyond what they agree to implement. It is important for each state to be able to continue to work on their own approach since nutrient dynamics can vary so from ecoregion to ecoregion.

    One of the largest challenges within Louisiana will be working quickly enough to save our coastal wetlands and finding ways to utilize these nutrients to benefit that effort. We have many wetland scientists and local decision makers helping but the task really is a large one. It will require everyone working together and pushing hard to make it work. Information from other states and their successes is encouraging so we will continue to work as diligently as we can to make progress, and we hope that EPA will continue to be supportive.

  10. March 25, 2010

    We have to find a meaningful way to actually regulate nonpoint source pollution in a context that allows some control. In rivers systems that are at their limit for allowing new point source discharges, there is nothing in place that prevents someone from tilling up to the ordinary high water mark and putting down pesticides and fertilizers which runoff into the river. This is aside from the tons of sediment that also makes it into the water. Excess nutrients and sediment are some of the biggest threats to surface water and until nonpoint source pollution is held to the same standard as point sources – improvement from this point forward will be unlikely.

  11. March 25, 2010

    One area where EPA could offer additional support and assistance with in helping states implement numeric nutrient standards is to provide data and evidence on the benefits of properly functioning ecosystem services. The Water Quality Control Act, Colorado’s implementation of the Clean Water Act, requires “economic reasonableness” with its regulations. Identifying the benefit of protecting water quality has always been a very site-specific exercise. It would be a great tool if you could develop some sort of method to show how much benefit, on a state-wide perspective, is derived from controlling pollutants, in this case, nutrients.

  12. March 25, 2010

    It makes no sense to require treatment of sewage to remove pollutants so clean water can be returned to waterways, and then turn around and spread the sludge of those same pollutants on the land where it is free to run off back into those same waterways. The practice of land applying sewage sludge biosolids needs to be recognized for what it is – using our agricultural fields as a dumping ground. This is the cheapest means of disposal for the municipality, a big profit maker for the biosolids industry, and a disaster for the landowner (now or later), his neighbors, and all who eat.
    Land application routinely applies up to 1500% extra phosphorus, to say nothing of the unknown and untold numbers of pollutants – all of which are free to seep into ground water and to run back into waterways with the first heavy rainfall. This practice must stop. Use the sludge for non-fossil fuel.

  13. Small Farmer permalink
    March 24, 2010

    Article 1, Section 8 of the U.S. Constitution does not authorize Congress to legislate in the area of the environment
    , therefore, it is unconstitutional. All 50 states of the Union have their own version of the EPA as authorized under the 10th Amendment. There is no need for a federal agency. The states of the Union can handle their own environmental needs as authorized by their legislatures.

  14. March 24, 2010

    Topic 2: Managing Pollutants from Nutrients
    Excess nutrients like nitrogen and phosphorous entering the nations waters create pollution that is hard to track, contain, and control. Nutrient pollution is as damaging to our waters as it is complex, so finding effective ways to address it is critical. EPA and State agencies have used various approaches to tackle the problem but much more is needed to protect water bodies from these pollutants.

    • What critical elements need to be included in an effective nutrient strategy?

    Response: Reading the 27 August 2009 EPA Report of the State-EPA Nutrient Innovation Task Group it seems quite obvious that the group has identified the greater “Root Causes” of nutrient pollution sources. If I understand the question I believe the most critical element for an effective nutrient strategy is Full Enforcement of current laws on the books against the perpetrators. Education seems to be a popular term. A program of education should be offered with emphasis on clearly communicating the known root causes, effective Elimination (not merely undefined minimization) techniques, and finally, the penalty structure for violations. The program should be plainly advertised publicly – not the small print in a public notice – and attendance should be voluntary. Polluters who choose not to be educated take the full risk of fine assessment.

    • How should the strategies differ for protecting healthy and functioning watersheds versus those that need to be significantly restored due to previous pollution?

    Response: The only strategic difference should be that, for those watersheds already in trouble, the polluting entities should be more easily identified, contacted, and corrected. Harsh fines, in accordance with current statutes, would be the most effective means to the end. Properly functioning watersheds, which are not affected by history of violations, may only require sample maintenance testing. All reports of violations, especially by citizens, should be taken seriously and the root causes addressed immediately.

    • What has worked for your organization, state, or tribe in controlling nutrient pollution? What hasn’t?

    Response: Unfortunately, I have no personal experience with a functioning control program, but have seen that voluntary or loosely controlled programs and/or un-enforced laws have disastrous consequences. Even our Governments have difficulties implementing effective programs – see Combined Sewer Overflows.

  15. March 24, 2010

    In my rural area we have CAFO’s. We have a spills in the past that turned a local creek PINK. They are allowed to stockpile, which should not be allowed due to strong odors, flies and runoff in to streams and creeks. The use of center pivots should be looked at alot closer also. There are three in my area and there is a stream by each one. Somehow that does not calculate as a smart thing to do. These CAFO’s use a lot of water not just for animals to drink but for washing eggs. And that water stinks. Our WELLS are at risk. I believe the CLEAN WATER ACT was to protect. I hope the USEPA stands-up for little guy.

  16. Chris Pachta permalink
    March 24, 2010

    As a certified crop adviser and a fourth generation family farmer I feel that farmers get a bad rap and are under appreciated for their environmental stewardship. A farmer makes their living off of the land and it makes absolutely no sense for them to not take care of that land so it will continue to be productive for them and future generations. I work to ensure that the land I farm stays productive and will be that way for my son if he decided to pursue my profession. Farmers continue to show they are good environmental stewards by continually adapting and developing new technologies and farming practices. Through the adoption of no-till farming practices in my area the amount of soil erosion has greatly reduced, along with it the run-off of nutrients and pesticides. Also, the quick adoption of new technologies in varieties (many of which are highly criticized by those outside of the agriculture industry) such as Bt corn and Round-Up Ready soybeans has greatly reduced the use of pesticides. Furthermore, the adoption of new precision ag technologies that allow for automatic boom section control, auto-steering, etc have allowed us to reduce over application of nutrients and chemicals and place them exactly where they are needed. The many farmers I work with as an adviser continue to adopt new technologies that help them be better environmental stewards. They pull soil samples and use university research and recommendations to apply the proper rates of nutrients and pesticides. Farmers invest to much money in nutrients and chemicals to not be good stewards of these products and accurately place them so that they stay where they are needed. Farmers have more to gain or lose by being good or bad environmental stewards than anyone else. The land is where we live, where we grew up, where we raise our families, and make our living.

  17. March 24, 2010

    In two watersheds of our area of the state, Missouri, we have over 190 million chickens raised each year. They use about 7 gallons of water per chicker per day. Think about the effects on the groundwater table. A large percentage of these go overseas along with the nutrients from corn, soybeans and other sources. Corn and soybeans need irrigation to prosper. Soil fertility is going to suffer as will our aquifer from these drawdowns. I propose putting a one cent tax-tariff-oversight cost to each chicken for environmental monitoring and soil testing. This in reality amounts to a mere 1/6th of cent per pound levy against chicken meat. Foreign countries are receiving our product and with it taking our vital water and nutrients used for food production. Worse of all we are using aircraft to transport these animals to China and other spots. We scream about the cost of oil and the amounts imported and yet we fly chickens to other countries, does anyone see the irony of the situation?
    The tax or whatever you want to call it will be used to monitor and control all litter movement within or outside the state boundries in a rational and ecological manner. Soil testing will be free to land owners wanting to receive the litter for soil enrichment. Haulers will be certified and be given coordinates for application, timing and amounts to be applied per acre. GPS locators will be used to monitor application sites to insure proper setbacks, slope of applied sites and timing of application. We need to insure that over application and improper placement is monitored and prevented.
    These are corporate farms and not family farms that are destroying our waterways and lakes with irresponsible litter placement.

    Another method would be to burn it for energy production as done in Minnesota with turkey litter.

    I also suggest that it be a national law for the health of the citizen that waterways, streams and lakes be labelled with a sign that show impairment for whatever reason. In our counties a vast majority of the streams are on the impaired list for bacteria and yet citizens are allowed to swim and recreate in these streams. Why doesn’t the Feds place the burden on state Health Agencies to post these streams with permanent signs notifying the citizens of this threat. At this time it is left up to county agencies to test and alert citizens of a possible threat. They receive no Federal, state or additional funding to provide for this expensive testing and notification work.
    Finally, all states with a significant number of CAFO’s, regardless of type or animal, need to limit their numbers of animal units based on the ability of the land mass to safely confine those numbers. Base this on water availability, litter placement or needs, environmental problems(odor, chemicals etc) caused by CAFO and the determint to land values of cities and homeowners.
    It has been shown in Oklahoma that the arsenic used in chicken feed has found its way into ground water, surface water and homes from the application of litter. What other states that cannot or will not test for these pollutants have similar problems? Grow up and get real it is not going to get any better.

    Many of these solutions can be said to be a “state rights issue”, but the states are not going to step on any toes or have ignored the problem for too long. Being adult means doing the right thing at the right time before it gets any further out of hand.

  18. March 23, 2010

    I believe that if you get the waste water treatment facilities to clean the water better so that there are less(hopefully none) chemicals, pharmacuticals, hospital, industrial etc. wastes being discharged into our waterways that will be a major change and a big help. Then , of course the sewage sludge will be even more toxic than it is now. We need to stop Land applying the sludge as there is no scientific proceedure to remove the toxins from the sludge. Use the sludge to produce energy and put the smaller by product in a safe landfill or other area.

  19. Ray Ruthenberg permalink
    March 23, 2010

    As a drinking water professional (now retired), I’m concerned about the aquifers becoming polluted -mainly by nutrient runoff from ag fields or by percolation of liquid manures into the shallower aquifers or into drain tiles, then into creeks. Manures from CAFO’s frequently contain antibiotics or heavy metals, and worsen the effects.
    Karstic substrates must be a limiting factor, and should actually prohibit CAFO’s. In those areas without karst, regulations should increase land spreading requirements per animal unit. States have limited funds to enforce regulations, and, if it is a federal reg, the feds should fund the extra inspectors.

  20. Andy permalink
    March 23, 2010

    I am a watershed professional working in the heart of Pennsylvania’s agricultural region, in the Chesapeake bay. I have noticed a lot of comments regarding agricultural NPS pollution, and they have all been addressing CAFOs (Concentrated Animal Feeding Operations). Pennsylvania has some of the most stringent agricultural pollution regulations in the country. That being said, most of these regulations are not only not enforced, they are more commonly not even known about within agriculture.

    When I look at Concentrated Animal Operations (CAOs) and CAFOs in PA, which are heavily regulated and enforced, I see very clean farms with good management and properly handled manure. All farms will have NPS pollution, forever. This is a fact of agriculture and the environment, even sustainable agriculture.

    However, the 44,000 or so small farms in Pennsylvania are not equally under the same careful scrutiny that CAOs and CAFOs are. This is not to say that none are scrutinized, but that by percentage it is night and day. PA has regulations in place that require farmers to have and follow a Manure Management Plan, an Agriculture Erosion and Sedimentation Plan, and a PA clean streams law to enforce gross pollution issues. Not being an expert in other state’s programs, I cannot speak for others, however I would suspect that there are similar regulations and/or guidance out there

    Providing funding for the education, development, and implementation to state Environmental Protection Agencies and County Conservation Districts for these practices by the EPA will reduce nonpoint source pollution tremendously. The best part of this approach is that no new regulations need to be developed, which means less enforcement.

  21. March 22, 2010

    Nonpoint source pollution is the largest source of N and P to major rivers, and most lakes, and most N and P come from agriculture. End-of-field measures are doomed to failure, especially for P, because they will eventually become saturated with P.

    The only long-term solution is to balance inputs with “deliberate” outputs (e.g, crops and animal products). This requires some refinement in regulation: for example, land application of manure is generally based on uptake of N, not P, which means that a farmer would always be overapplying P relative to crop needs, by a factor of 3-4. P-based manure limits would restrict the size of feedlot agriculture, because more land would be needed to apply manure, but it would greatly reduce P in runoff.

    Beyond this, probably the best approach is to assist farmers within a watershed by conducting farm and watershed nutrient balances and providing feedback in an adaptive management framework. Most farmers would probably participate voluntarily, and would learn from early adopters. For animal ag, much of the focus should be on N and P inputs, seeking greater efficiency of utilization. The advantage to farmers would be more efficient utilization, and hence greater profits. Small farmers would benefit the most; large farms the least, because they already know this. Government agencies should track net P accumulation and seek to reduce it. Over time, this will result in lower stream concentrations.

    Finally, it is past time to eliminate farm subsidies, because these encourage greater yields than market conditions dictate, and compel farmers to overapply nutrients to achieve artificially high (in an economics sense) yields.

    Weirdly, the best farmers know all this, but government agencies persist in supporting end-of-field practices rather than watershed-scale nutrient balances (esp. P). I think this is a cultural carryover from wastewater treatment, which worked very well for municipal sewage. The proof is in the pudding: this hasn’t worked.

  22. March 22, 2010

    I propose a green infrastructure solution that PREVENTS sources of agricultural water pollution. It addresses not only ways to prevent water pollution but stems from a means that will make our nation energy independent from a renewable fuel, increase the food supply and improve it’s quality to enhance human health and reduce health care cost, and create millions of jobs in rural communities to solve our nationwide unemployment problem.

    The solution is to create thousands of small to medium sized, permaculturally designed farms growing food for both human consumption and as feedstock to produce ethanol. The ethanol production process generates by-products that are naturally nutrient rich. These by-products are then used as fertilizer and pesticide for the next crop, as healthy feed for livestock, and in many other productive and sustainable ways. When these by-products are used as fertilizer and herbicides, they produce outstanding yields, even higher than what has been achieved from chemical based fertilizers and herbicides.

    Chemical based fertilizers, while contributing for years to supplying the US and many other nations with food, are a major source of groundwater pollution that has created an 8000 square mile dead zone in the Gulf of Mexico at the mouth of the Mississippi where fish go to flounder and die. Using the nutrient rich by-products as fertilizer and herbicides from thousands of small to medium sized ethanol producion facilities on family farms throughout our nation will eliminate the groundwater pollution caused by chemical fertilizers and over time heal the dead zone in the Gulf.

    Using the ethanol to fuel our vehicles instead of gasoline will take advantage of ethanol’s superior combustion properties versus gasoline to significantly reduce our nation’s air pollution also.

    The organic foods grown on these farms will be locally available, fresh, taste better, and improve the health of the community residents. This, coupled with the excellent exercise millions will receive by working at these numerous facilities, will decrease health care cost and make unemployment a thing of the past.

    Also, a specific green solution to reduce the chemical pollution caused by our nations thousands of water treatment facilities is to use cattail marshes to soak up the nutrients in sewage that the current polluting chemicals are trying to neutralize. The cattails can then be used as a terrific ethanol feedstock with yields that are 33 times greater than corn on a per acre basis.

    Based on his 35 years of worldwide research and his successful application of these sustainable solutions, David Blume has written books and numerous articles with infinite detail on how to transform these solutions into a nationwide reality.

    I am strong proponent of solving our nation’s problems in creative ways that encourages and empowers individual citizens and gives them hope. The United States has evolved into a society where misdirected capitalism and a misplaced desire to regulate and control has created national companies and a national government that have both grown too big to best meet the needs of individual citizens, especially in rural areas.

    My comment to the EPA would be to spend less time trying to regulate us to solve problems and use your authority to gather facts about the sustainable techniques listed above and educate and incentive citizens to adopt them into a business to make a meaningful living and in so doing solve the problems of pollution, foreign oil addition, poor health, and unemployment that effect us all.

  23. March 22, 2010

    Managing nutrient and other pollutants requires knowledge of loads by load source and the efficacy of BMPs aiming to reduce those loads. With that knowledge one can create a “pollutant load reduction efficiency matrix” for a given BMP. This matrix tells the amount of load reduction possible from implementing a given practice (say, a riparian forest buffer) on a given site (say, down-gradient from a field of row-crops). At a fixed price per unit pollutant reduced, one simply multiplies a given cell in this matrix by the fixed price and, in this way, one will have optimally targeted load reduction at current technology. Potential adopters can then know the value of various BMPs for reducing pollutant loads and, will be likely to choose those that bring them the highest net return — which will be precisely the practice that, technically speaking, we would like to have them implement.

    This would require a fundamental shift away from “per acre” pricing for pollutant load reduction BMPs to a “unit reduced” pricing system.

  24. March 22, 2010

    Having read through the comments, one essential component of a strategy for abating nutrient enrichment appears to be consistently unrecognized. Specifically, the link between the hydrologic cycle and habitat quality should be a cornerstone for managing nutrients from nonpoint sources. A comprehensive strategy in this regard would involve restoring soil quality (especially with respect to soil carbon) through crop management, mimicking a natural nutrient cycle between the soil, crops, and nutrient amendments, changing the way tile drainage is practiced to include both controlled drainage and directing outlets to created/restored wetlands, expanding riparian zones for processing and assimilation nutrients, and restoring the physical habitat quality to ditched streams, again, for greater assimilative capacity, but also for a host of other benefits.

  25. March 22, 2010

    The Clark Fork River just completed a 10-year Voluntary Nutrient Reduction Program that was a successful means of lowering N and P levels in the river, and a partnership between several cities and point-source dischargers (industries) in Montana and Idaho. While the program went a long way to improving water quality, the main culprit of nutrient pollution in much of the upper river in this 22,000 square mile watershed is non-point source pollution from agriculture.

    Voluntary approaches work well, but only if coupled with a nutrient standard or other regulatory limit that sets the “goal” for how and why folks should participate in voluntary approaches.

    We also believe that the Northern Rockies watersheds would benefit from an established framework for an incentive-based “pollution mitigation credits” that allows landowners, cities, and businesses to “offset” their pollution–both point and non-point source–similar to approaches underway in the Midwest.

  26. Ann Straut-Esden permalink
    March 22, 2010

    Agriculture is a large problem with nutrient loading. However, another issue facing some states is what the state above them is doing about nutrient loading. A state can enforce all the NPDES limits it wants within its jurisdiction, but if what is entering into their state via the waterways already exceeds the limit, there is no way they can meet the limits EPA is proposing for nitrogen and phosporous. More broad-based plans and enforcement may be needed for states to get interstate cooperation for nutrient reduction.

  27. Tricia Schuster permalink
    March 21, 2010

    Spreading sewage sludge as fertilizer is increasing pharma loads, heavy metals and other contaminants in our groundwater. Since sludge was spread in our community, wells have been contaminated and nitrate levels have spiked. The EPA’s own testing at water treatment plants shows unacceptable levels of toxins in sludge. Start protecting our water supply by prohibiting the spreading of sludge.

  28. March 20, 2010

    I have been involved with water issues in my state for the last 9 years. Mainly because of a cafo issue in my community. Resulting in dealings with multiple state & federal agencies for about 3 to 4 years. The issue was resolved with an estimated 2 to 3 square mile area contamintion plume in a alluvial aquifer. Pollution was nitrates later confirmed to be animal by radio isotope testing. The issues that was noticed by myself and others is lack of funding for inspectors at both levels state and federal levels and then after a case is resolved fines are not realistic. Especially dealing with bad actors. My recommendations are this, more funding for state and federal agencies. Better communication between the agencies state and federal. Creation of a joint taskforce for dealing with Bad actors. More help for communties when dealing with the agencies, an omsbudman if i spelled that correctly (in our case it took 4 to 5 weeks to properly identify the agency we had to contact and then another 3 or 4 weeks to get an appointment to meet with them.) That is what we have learned in our journey in that water issue we had before us and we are still learning. Here is a true saying in my neck of the woods whiskey is for deinking and water is for fighting for.

  29. March 19, 2010

    It is well-known that about 95% of phosphorus (P) in rivers is on soil particles, so keeping soil in place must be a very high priority. Most of the problem of (P) in estuaries and rivers is due to dams being demolished and legacy sediment being washed downstream, and other dams loaded with silt so that any new silt added to rivers is forced to go over the remaining dams as well. We need to make sure that our computer models estimating damage to ecosystems are not flawed, and that costs of “cleanup” do not exceed benefits.
    The Lancaster County PA Conservation District and the Lancaster County Farm Bureau have developed a “Fence ‘Em Out” plan that encourages fencing livestock out of streams similar to the “flexible fencing” program of the Shenandoah Valley, VA which can be replicated widely.
    No-till and limited-till plans are growing in popularity nationwide and can be encouraged further.
    Educational materials on holding nutrients in place on soil can be disseminated widely. No one wants valuable nutrients to be wasted or washed away, but figuring out how to keep them where they belong despite the vagaries of nature can be costly. More progress is made with a carrot than with a stick.

  30. March 19, 2010

    Thank you for taking stock of where we are in water pollution- comments so far are encouraging, and great progress is being made. EPA deserves much credit!
    Some serious problems in groundwater and stream pollution deserve increased public and industry awareness, much as water conservation efforts by many communities are paying off, even though it has taken much effort. So should we shrug off stream polluters? We can and should go after fixing the things we now can and need to fix. It will take years and many contaminants may not be controllable-yet. Let the mindset begin; start with those things we can control but may not have tried yet. Or perhaps dismissed as too small to worry, or always been there naturally; Stormwater runoff can’t be prevented–etc.
    Contaminants in streams threaten all down streamers and oceans and bays cling to them despite apparent dilution, to “within limits.”
    Selecting one among many “fix it targets” FLOODS deserve more preventive attention than they get. National loss in flood claims exceeds $8.0BIL/year plus cleanup and deductibles that are not even tabulated by anyone (NWIS has best try). Considering that most of that flood water has left various levels of pollution in other ground water plus basements, fields, farms, businesses, schools, etc., its time has come. We set out to study just this area in two local counties and streams carry much potential pollution to the harbors and beyond.
    We do not need to push geotextiles but they do offer a new solution to capturing large enough potential flood waters (which can now be better tracked or predicted). If we test, identify source, and tag basics with estimated volumes we could add an investigative tool at very low cost. Running down the smoking gun is a new threat to those who ignore regulation of polluting the environment presuming they will not leave a trail. We have patented a tool for this for other purposes like capture and fix streams, but in application it has to be looked at seriously because it will provide jobs that can pay for themselves. USACE will test this marvelous textile in June in Mississippi for another good purpose, and they started looking at it in 1989 so it is catching on as a strong new tool in water management. It has definite application in places like Florida which can be useful in infiltration of aquifer with high quality water, to attack a much polluted aquifer problem where reservoirs are too costly.
    Fixing floods before they flood, and capturing significant amounts of polluted water so it can properly be treated (and returned or marketed) is now possible. It involves as many as eleven federal agencies to work together. And it is a project that will take time to do it right but will pay for itself with environmental dividends. Details are available.

  31. March 19, 2010

    The US needs to phase out land application of raw manure. One reason is the scale of CAFOs (in animal units, $, and lobbying influence) is overwhelming rural communities. But an equally good reason is that we need the energy that could be generated by manure digesters. Digesters have their own issues with effluent and biosolids, but we have technologies and standards to handle those materials.

    The costs should be borne in food costs — milk and meat should be more expensive than they are today. US consumers have, and will continue to have, plenty of alternatives in a food system as productive and varied as we have in the US. Scaremongering about food shortages is ridiculous when we are talking about food production as inefficient with calories and nutrients as CAFO-derived meat/dairy.

    CAFOs that apply raw manure to land are repeating history — a new industry looking to minimize responsibility for their pollution. They should be regulated by the same agencies in charge of other factories (not agriculture agencies). I live in an Ag state near the largest CAFO (we have only 2 cities that could beat it in fecal production), so I am not holding my breath about the last point (it is spring manure speading season — we have other reasons to hold my breath). Unlike another commenter who thought government regulators are on top of CAFOs, we have not seen or heard of any engagement or concerns by USEPA. That is why I think we need a more direct approach such as a federal ban on raw manure application.

  32. March 19, 2010

    For now the simplest things we can do are restrict phosphorous in lawn fertilizer, identify and get communities to address failing septic systems,
    get the stubborn farmers to understand the value in small riparian buffers along side ditches and small tributaries, and locate and find all the small illicit pipes discharging small amounts of wastewater and grey water into streams in our Township. The big challenge will be dealing with all the new emergent pollutants , medications, and endocrine disruptors now accumulation in our rivers and streams.

  33. March 19, 2010

    There should be better control of fertilizers and weed control products that are used by the public. Education on their frugal use would improve the quality of stormwater runoff. It might even be necessary to place restrictions on their use.

  34. March 19, 2010

    Commenting on the pharma loads beginning to show up in our fresh water supplies… The rule of thumb stipulates that complex molecules ie; statins and certain biological hormones will break down after @ 40 days exposure to UV and other biological filters. Of course rules are made to be broken. The savior in waiting seems to be nano technology. Nano filters capable of filtration .001 microns>.01 filtering very low molecular weights. ie; multi valent ions, viruses and bacterias. Complex molecules will definately be filtered. Like any technology, cost is the key.

  35. Loni Kemp permalink
    March 19, 2010

    Agriculture is the largest source of nutrient nonpoint pollution. Until we find a way to limit nutrient runoff from farms and feedlots, we will not have cleaner water. The major hurdle to controlling nutrient runoff from farms has always been that farming is very complicated, and farmers can use a wide variety of management practices to successfully limit runoff and leaching of N and P. Simple regulations and traditional enforcement are impossible – and unpopular.

    USDA has developed a new farm environmental performance measurement tool that may be the answer we need. The Conservation Measurement Tool is a simple questionnaire that asks a farmer a variety of questions about what is grown, what farming practices are being used, and what the site is like. A numerical score is produced that reveals if the overall performance of that farm is successful at not degrading resources, and how well they are doing overall. Developed for the Conservation Stewardship Program by a wide array of scientists, this tool could be streamlined to focus on water quality. It finally offers the regulatory tool states have needed to implement a TMDL plan to reduce farm runoff of nutrients (and sediment and pesticides if they choose to.) With spot-checking and verification, society would get pollution reduction from agriculture without oppressive prescriptions for how to farm.

  36. March 18, 2010

    In Connecticut there is an agricultural exemption, even one horse as a hobby is considered agriculture. As a result, nutrient loading into wetlands and watercourses does not fall under our jurisdiction.

  37. Cliff White permalink
    March 18, 2010

    The two biggest challenges are funding and appropriate use of those funds. The Clean Water Act and associated grant programs from the 1970’s and 80’s have been good catalysts with regards to upgrading treatment from point sources. However, with the prodding of special interest groups (I hesitate to call them environmentalists), regulations have been blindly enforced and followed, sometimes with little of no benefit to the environment. For example, many municipal point sources were required to upgrade their facilities while neighboring private systems and agricultural activities, including lawn maintenence were allowed to continue to pollute. The net result is little improvement in stream quality, and the money spent on the improvements was essentially wasted. The technology to control nutrients is not a mystery. The question is societal, are we willing to pay $3, $4, $5 for a gallon of milk in order to fund pollution control measures at CAFO’s? or pay $10/1000 gallons of wastewater to replace aging infrastructure? You get the idea. Ballancing pollution with economy. We’ve all been quick to point the finger at certain groups and industries as polluters, but it is taking individual responsibility for our actions, either by changing our consumption habits and/or paying our fair share to manage the environmental by-products of those items we chose to use and consume.

  38. March 18, 2010

    As watershed conservationist for the northern 4 counties of Indiana I am forced to deal with two very large watersheds, Lake Michigan and Kankakee. Both suffer similar nutrient and sediment loading problems however focusing on the LM watershed solves many problems. Nutrient loadings from Indiana sanitary effluents into Lake Michigan look something like this.

    N…10,500,000 lbs/yr
    P… 2.300,000 lbs/yr
    K… 2.300,000 lbs/yr all +/- 12%

    These are biological loads not reflective of manufacturing or commercial type loads released into Lake Michigan. If we widen our perspective to include Illinois Wisconsin and Michigan, the nutrient numbers soar astronomically. Lake Michigan holds @ 1,180 cubic miles of water. At what point do we reach maximum load tolerance?
    No one seems know. It seems reasonable that if we continue to allow these amounts of Nutrients into Lake Michigan at some point in the near future we will reach a cascade event that will evolve into dead water.

    Considering the fact that our populations are still increasing it is logical to assume our nutrient loads will increase also. There is only one ZERO DISCHARGE program that I am aware of, that being proposed by the Center for the Transformation of Waste Technology for the Hammond Water Reuse Project. This is an extremely ambitious project based upon using effluent as a nutrient delivery medium for row crops and open spaces. Considering 40% of broadcast fertilizer winds up as run off and 2.5% of that enter into Lake Michigan, this seems to be an excellent answer to a huge problem. If anyone is aware of other systems or projects capable of removing this volume of nutrients please let me know as soon as possible

  39. Clark Kinnison permalink
    March 18, 2010

    Our farmers and ranchers have a monumental task…

  40. Clark Kinnison permalink
    March 18, 2010

    I live in a state where the livestock industry means
    $6 billion-plus to our economy. Our have a monumental
    task – to feed the world!
    I believe the EPA has done, and is doing a really good job (contrary to an above comment) in regulating CAFO’s
    (Confined Animal Feeding Operations). Keep in mind that some comments that will appear on this page will be from folks who despise larger CAFO’s. However, these operations are very stringently controlled by both the EPA and state regulatory agencies. In the past few years, the EPA has stepped up it’s regulation and enforcement of these operations and I truly believe has been very successful in preventing runoff from these types of operations. The rules and regs are in place and are working for CAFO’s. Congratulations!!

    In reading other comments on this site, it would appear there are real problems from human waste and the proper treatment and the regulation thereof. It seems that this is where perhaps some of our current problems lie. However, in all the discussion here, I hope the EPA will recognize the tremendous strides that have been accomplished in the past! When I was young, I recall a river back in Ohio that was on fire! Things definitely needed to change. And, they have!!

    I believe we already have enough rules and regulations in place to effectively manage water pollution. There are those however that hold standards so high they would be unachievable. Standards whereby the rivers and streams were NEVER so pristine, even before the United States was a country. Please keep this in mind as you discuss this issue. The pendulum has come back to the center and I fear it will keep traveling and our farmers and ranchers will be regulated out of business; leaving us to rely on only imported food. If you like being dependant on imported oil – YOU’LL LOVE BEING DEPENDANT UPON IMPORTED FOOD!! OUR FATE WOULD BE IN THE HANDS OF OTHER NATIONS.

  41. Andy permalink
    March 18, 2010

    Nutrient reduction is a problem that takes years to surface, and will take years to fix. EPA should focus on helping municipalities upgrade and improve existing sewer and wastewater treatment facilities. The current systems have been in place for decades and will only degrade further without significant improvements. Contnuing to focus money and efforts on non-point runoff, without these improvements, is like spending all your money on shoes andthen realizing you don’t have a dress for the dance.

    Another significant problem is understanding what is attainable. Without natural background baseline data no realistic reduction goals can be set. At a recent meeting evaluating some USGS BMP’s, the presenter noted that after a period of time they only noticed a 30 percent reduction in phosphorus. When asked “How do you know that is not a huge reduction?” the presenter didn’t know how to respond. As it turns out, 30 percent was a significant reduction based on the naturally occuring organophosphate levels in the soils.

    EPA should continue to workwith USDA to encourage the impliementation of BMP’s for agriculture and construction stormwater runoff. If the goal is improving water quality, we need to focus the majority of funds and efforts on the nations failing sewer and waste treatment facilities to get the biggest bang for our buck.

  42. March 18, 2010

    Requiring disclosure of location where manure is spread is essential. There are loop hole that allow for manure management plans to be a single line, “brokered to third party for distribution and utilization”, at facilities generating 200,000+ tons per year. There is no requirement for the distributor to report field location or soil test data of current nutrient levels. I am baffled that this can go on in watersheds that are receiving millions of dollars from the Conservation Reserve Program, and so are the farmers in my area.

  43. March 18, 2010

    Any nutrient pollution policy must address non-point source pollution — agriculture. It is time to stop giving crop and livestock operations a pass. Voluntary measures haven’t worked.

    Municipalities have wastewater systems and stormwater system (or combined systems) that treat wastewater to standards except in heavy precipitation events.

    Why shouldn’t CAFOs treat their waste to the same level, and why shouldn’t crop operations be required to prevent runoff of chemicals?

  44. March 17, 2010

    it seems we could improve greatly by doing relatively obvious and simple things such as:
    1- better monitoring of, and better regulations for, the the storage of refuse from high density animal operations/feed lots, which too often is in an unprotected pile, just waiting to wash away in a hard rain
    2- banning phosphates in detergents
    3- requiring gardening stores to carry phosphate-free fertilizer and promote it for all lawn except those being newly established

  45. March 17, 2010

    Develop and enforce a TMDL for every watershed.

    Identify biological treatments to clean water without expense of customary water treatment.

    Alter codes to allow grey water use. Require cisterns and use as flushing water and irrigation.

    Mandate vertical growth vice horizontal sprawl. Eg. build a parking garage versus five acre parking lot.

  46. March 17, 2010

    In the city where I live, our surface waters have excess nutrients but agriculture is not the issue. The issue is human waste. The sanitary sewer is gravity-fed, so the lines run along the creeks and the manholes are oftentimes in the middle of the creek or in the riparian area. Our sewer is aging and regularly has overflows or breaks and only a portion of the city is on sewer. We regularly have bacterial and nutrient exceedences, indicating septic and sewer problems. Due to a budgetary crisis and high costs, the city can’t afford to repair and maintain the sewer adequately, let alone expand the sewer connection to non-sewered developments. The city no longer qualifies as “rural” for USDA Rural Development grants and loans. Therefore, federal grant or low-interest loan programs specifically aimed to improve, repair, and expand wastewater infrastructure would do wonders for surface waters in many areas. We can restore riparian buffers and implement BMPs all we want, but if the sewers and the septics continue to leak, we will never get on top of our nutrient issues.

  47. March 17, 2010

    There is an urgent need for EPA to define “propose to discharge” in the context of federal CAFO regulations. There needs to be more money for states to inspect CAFOs.

  48. March 17, 2010

    I was thinking about wet scrubbers used to control air pollution control. Incinerators use packed tower and recirculate part of the wastewater. The packing material gives a surface area for collection and chemicals are used to control the pollutants. Packed towers do not take up alot of space. You could feed a contaminated pond to it. Packed Tower Aeration is a process for the removal of organic contaminants from groundwater. The groundwater flows downward inside a tower filled with materials (the packing) over a large surface area. Air is introduced at the bottom of the tower and is forced upward past the falling water. Individual organic contaminants are transferred from the water to the air, according to the gas and water equilibrium concentration
    values of each contaminant.

    Chemical precipitation processes are often used for the removal of heavy metals and phosphorus from water streams. Like air pollution adsorption processes, activated carbon is the most widely used adsorbent. Water may be passed through beds of granulated activated carbon (GAC), or powdered activated carbon (PAC) may be added in order to facilitate the removal of dissolved pollutants.
    microorganisms consisting mainly of bacteria convert carbonaceous matter as well as cell tissue into gas.

    I have seen literature for the removal of phosphorus from wastewater in an efficient packed bed contactor. Adsorption capacities are high, and kinetics rapid, such that a contact time of less than 5 min is sufficient for removal of 60―90% of the phosphorus, depending on the feed concentration and time in service.

  49. March 17, 2010

    Even though most human waste is treated before being released into the environment, there are no requirements to reduce or eliminate pharmaceutical residues in our wastewater. As the US population relies more and more on pharmaceuticals for treatment, more and more residues will end up in our water environments. The effects on us and the environment need to be understood.

  50. March 17, 2010

    As a global trade association, the Methanol Instiute highly recommends the use of methanol based denitrification to battle excess nitrogen and nutrient pollution in our nation’s waterways. Denitrification is a process involved in the treatment of wastewater. As wastewater is collected in a treatment facility, it contains high levels of ammonia. Through a bacterial degradation by facultative anerobes, the ammonia is converted into nitrate. Methanol’s strength is in its chemical makeup. Known as “wood alcohol,” methanol is a simple molecule (CH3OH) that serves as a carbon source for bacterial “bugs.” Accelerated by the addition of methanol, anaerobic bacteria rapidly convert the nitrate to harmless nitrogen gas, which is vented into the atmosphere. Methanol is readily degraded under anaerobic conditions, making it an ideal component of the denitrification system.

    Today, nearly 200 wastewater treatment plants around the United States are using methanol in their denitrification process. One of the best success stories related to methanol denitrification is the Blue Plains Wastewater Treatment Facility. Blue Plains, which serves the metropolitan Washington, D.C. area, releases nearly 370 million gallons of treated wastewater to the Potomac River each day. As a result of its size, the Blue Plains Wastewater Treatment Facility is the single largest point source of nitrogen for the Bay, at 20 tons of nitrogen per day. With methanol denitrification, Blue Plains has continually met the EPA standard of 4.7 million pounds of nitrogen released per year, and has come in well below the standard on many occasions.

    Nutrient pollution is certainly a problem plaguing our waterways, leading to algae plumes and the eutrophication of sensitive water bodies. Denitrification is the solution and methanol is the key component in this ingenious system. The Methanol Institute stands ready to assist the nation’s wastewater treatment community to adopt this clean water practice.

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