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Welcome to Coming Together for Clean Water

2010 March 16

Nearly 40 years ago, Congress passed a truly remarkable piece of legislation—the Clean Water Act. This document outlined sweeping commitments to restore and maintain the integrity of our nation’s waters, rid them of pollution, and make them safe for humans and wildlife alike.

For even longer, the Environmental Protection Agency has worked to fulfill these ambitious and important goals. Our efforts have made our water resources cleaner and safer in many ways, but new challenges arise everyday.  This April, Administrator Lisa Jackson and I are inviting 100 leaders in water issues to help us sharpen our thinking during a one-day event, Coming Together for Clean Water, on how we can meet these challenges.

Specifically, we’ll discuss what we can do about the most significant pollution problems facing our waters. These evolving issues pose complex challenges to restoring healthy watersheds and creating sustainable communities across the country.

These priorities are important to all of us, and cannot be achieved in one day. That’s why Administrator Jackson and I are asking you to participate in this discussion forum, which was designed around the questions we’ll tackle during the Coming Together for Clean Water conference. I encourage you to share your thoughts and experiences on these topics, so we can use them to inform our discussion.

Addressing water pollution is an enormous task that will take a variety of ideas and experiences. I thank you for helping us in this effort.

–Peter Silva
Assistant Administrator for the Office of Water

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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89 Responses
  1. March 23, 2010

    I certianly agree with the concept of state regulation as opposed to one size fits all regulation from the Federal Government. Paul Harvey used to say self government withouth self discipline is self defeating”. The best solution is for individuals and corporations to act responsibly without government coersion, ie, to live by the golden rule of “do unto others as you would have them do unto you”. For that we would need a spiritual revival. (Would the EPA consider praying for a revival?) Absent that we need government regulation, once again state level regulation is to be prefered.

  2. March 22, 2010

    Many years ago, the EPA concluded that all of the Big Pipe Waste Treatment Plants that were needed had been built using substantial grants from the Federal Government. Then out came a report, probably 8 years ago, about OSWTS (septic systems etc) with the promise that additional materials and information would be developed and made available to the public.
    The silence from EPA has been deafening. Millions of additional systems have been placed in the ground and it is extremely difficult to educate the public that they even have a septic system, never mind that it is their responsibility to maintain it.
    I follow the EPA decentralized listserve and there unquestionably are excellent arguments against the big pipe solution besides, no-one can afford tertiary treatment plants.
    Funds should me made available to the states to assist in the finding and fixing (cost share as in TMDL 319 grants) of failed septic systems as well as predicating federal funds on forcing stricter regulations and mandatory periodic inspections by the states.

    Another extremely serious situation is that we determined that “silt” is a pollutant but the rules regarding siltation prevention and enforcement are terribly lenient. Again here, federal funds should be held as the incentive for the states to enforce pollution regulations.

    Granted there are terrible economic times but a little funding will go a long way.

    On the positive side, we were extremely happy to see the reallocation of funds in FY2010 to examine the downside of the chemicals (unidentified due to trade secrets) being used in fracturing to enhance production of natural gas.
    Thanks for the opportunity to share.

    Another speaker asked how the 100 technical experts were being selected and it would be excellent to see their names and interests.

  3. March 22, 2010

    Weave Climate Change Adaptation into all EPA program areas and provide modeling programs for Temperature Increases correlated to projected regional climate change air temperature increases under the various IPCC scenarios. This information is vital to establishing a true picture of water temperature increases over tim.e, and then management strategies, for especially the TMDL, ESA and Temperature Standard program areas.

  4. March 22, 2010

    I have worked in the water and environmental management public sector for 39 yrs. (currently retired) and have seen many programs come and go but the Clean Water Act seems to be something which will last for generations. However, the act is missing some vital components which can assist state and local officials and landowners accomplish what needs to be done to truly protect our waters. Following are some of my ideas:
    1) When an impaired water is determined to exist and a management plan is put into place, there should be mandatory requirements for landowners to participate in identified implementation activities.
    2) The EPA needs to start new dialogue with USDA and Congressional “Farm Bill” authorities on permanent ways to implement land uses that minimize impacts upon the most sensitive lands that impact our waters.
    3) In followup to item 2) above, the Congress needs to recognize that the “Farm Bill” should be modified to solve farm environmental problems from a sustainability perspective for future generations. This leads me to believe that rather than paying farmers commodity subsidys, we should pay them for good conservation practices. This would not only help the environment, but also minimize the criticism of farm subsidies from the rest of the world. There is a program, CSP…….currently on the books, which could go a long ways to address this issue if fully funded.

    Thanks for the opportunity to comment.

  5. March 22, 2010

    The EPA needs several things in order to be functional and restore our waterways, including restoring/preserving our national watersheds.

    1. There are too many UNENFORCED regulations, laws, and guidelines. Elimination of those that are no longer functional is necessary.

    2. There are too few people available to monitor water conditions. Development of a modern-day CCC that would be responsible for testing, cleaning, replanting, and whatever else it took would create jobs for the unemployed and alleviate the critical understaffing the EPA is forced to contend with.

    3. Legislation needs to be enforceable, with severe penalties for offenders, and criminal sanctions against repeat offenders.

    4. Focus on disruptions caused by destruction of the natural environment cannot be bypassed when dealing with these problems. Central Appalachia is being destroyed with the endless destruction of streams necessary to sustain the biodiversity of the region through surface mining. The dumping of “overburden” (that’s mountains that have been blasted to hell and the trees that were growing on them) into valleys and streams is a travesty that disrupts watersheds, pollutes the water (through dumping of chemicals used in the blasting process), and leads to ever-worsening flooding for local residents.

    5. Maintain this focus through vigorous monitoring and enforcement. Make the polluters, whoever and whereever they may be, pay the real cost of their pollution. If a municipality dumps sewage into local waterways, make them responsible for cost of cleanup. If an industry damages a watershed or pollutes local waterways, make them pay the full cost of cleanup. Financial responsibility can go a long way to change behaviors and to encourage the development of creative solutions.

  6. March 22, 2010

    I have long thought that the policy of forcing all sewage through the same plant is a serious mistake. Household and street wastes should be treated together. Industrial wastes should insofar as possible be treated on site.
    This would permit a much more specific and efficient treatment.
    And yes, I know, this is never going to happen, but that is what my aquatic ecology background informs me.

  7. March 22, 2010

    We have been implementing TMDL watershed projects since the Conservation Districts were created in Idaho in 1946. Approaches that are working are implementing Best Management Practices (BMP’s). Our monitoring folks found a 65% reduction in bacteria in a watershed we had targeted with BMP’s for livestock. We created buffers, installed off-stream water, installed roof runoff structures and worked with pasture management. We work on a voluntary basis with our producers. The producers are great to work with here. They are innovative and willing to make changes to their operations that benefit the environment, and water quality. The largest barrier to the implementation efforts are the costs involved. Cost share programs are the key to implementation efforts. Following our programs with monitoring efforts to assess the strides toward meeting TMDL goals are often a missing link as we face economic challenges and downsizing. Increased funding opportunities for monitoring would allow us to assess our implementation efforts. For most of the implementation efforts seeing the effects is a function of time – most problems did not occur overnight – improvements now to these problems will be realized over time just as the problem occured over time.

  8. March 22, 2010

    Without government intervention, companies like Nestle would drain dry natural water supplies just for a buck. What the average citizen is unaware of is that corporations are capable of massive amounts of damage unless someone steps up to the plate to keep them responsible in handling our resources.

  9. March 22, 2010

    A topic that needs further emphasis is the contribution of rural areas to pollution of the Chesepeake Bay and its watershed.

    I live in a rural county in Virginia, probably not unlike other rural areas in the CB Watershed. %90 of our residents are on traditional or engineered septic systems that often fail. These conditions have contributed to nearly all of the streams, rivers and bays abutting our county to have significant areas closed to the taking of shell fish because of fecal coliform pollution as well as significant nitrogen and phosphorus pollution.

    I would suggest that the EPA develop a model ordinance for septic systems using best practices from across the nation for design, construction and maintenance of septic systems. Until this is done a hodge podge of practices will evolve and this contributor to CB pollution will not be addressed. For example, the State of Virginia has enacted legislation to require minimum standards for engineered septic systems, that in my opinion are inadequete,and will impact this issue for years to come. See:

  10. March 22, 2010

    The first thing government can do is directly inform the public health department of bulk water dispensing practices at events that they regulate. They have no idea of the harm bottled water causes and need prompting to offer alternative ideas such as using a refillable 5 gallon dispenser at events.

    Also, the EPA needs to get their teeth into the game. For too long they have been afraid to enforce pollution controls. It evident that they have lost their courage. Time to take it back.

  11. Lynn M Stuter permalink
    March 22, 2010

    The best way to clean up our water is for the federal government to get it’s nose out of Tenth Amendment issues that do not concern it; ie, the water and waterways within the states are the business of the states, not the feds. If the feds feel a need to do something, why don’t the feds clean up the stench that flows past their doors every day, namely the Potomac River that runs brown because of polution! That the feds have done nothing about the river over which they DO have jurisdiction makes it apparent that, like everything else they do, the motto is “do as I say, not as I do.” I say, clean up your own house before you stick your nose in where it doesn’t belong. The united States is the union of states. The federal encroachment on states violates the U.S. Constitution which gives the feds LIMITED POWERS no given the states. Get out of the business of the states.

  12. March 21, 2010

    The best thing for the water in Montana is to keep the EPA out of the state!!

  13. Brad permalink
    March 21, 2010

    Stop mountaintop removal coal mining in Appalachia.

    This mining is literally poisoning headwater streams.

  14. March 21, 2010

    The EPA could do a lot to clean up the nation’s waters by ENFORCING the Clean Water Act. In Missouri we have county governments bulldozing sections of the Ozark National Scenic Riverways and actually changing the courses of the Jacks Fork and Current Rivers. It has taken five years of citizens’ complaints about Texas County’s bulldozing to get any justice and that has come too slow and too little to do any good. The gravels, soil and sand disrupted by that 2004 insults has long floated down to the DEAD ZONE in the Gulf of Mexico.So far Shannon County’s destruction of Big Creek on the Current has gone unchallenged accept by citizens and we are laughed at by our County Commissioners.

    So here we have cases of counties destroying parts of America’s first National Scenic Rivers, supposedly federally-protected rivers. What does that mean??? If a foreign power were to commit these acts, we’d be at war. Because some ignorant and stupid county officials do this, they get off the hook. When someone robs a bank or attacks someone, we don’t ask the victims to wait five years for justice!!! If the EPA won’t protect the best and supposedly the best-protected rivers inthe U.S., what good is the EPA???

  15. March 21, 2010

    We are currently fighting against a mine that wants to locate in the watershed of Canton Lake, Canton, Illinois. Since this is the cities water source and we have city water we do not want to take the chance that the water will be polluted by the mine operations. This same mine has over 300 documented water violations in Industry over the past 5-6 years. We are determined to keep such a polluter out of the location that they have chosen. There should be more stringent laws, (that are upheld), against a business that pollutes over and over again. It serves no purpose to have laws that are so weak they do no good or lawmakers who do not come down very hard on the side of the laws. If the IDNR and IEPA would do their job correctly we citizens would not have to be spending their time and money to undo their mistakes. It is ludicrous to have Governmental Departments who do not do their jobs and they should be reprimanded and the people within that department that are incapable or unwilling to do the proper investigations before the permit is issued should be dismissed. We need stronger laws that are upheld. A small fine does not deter a company from breaking the law. It needs to be a big fine and a jail term for the investors who are fronting these businesses.

  16. March 21, 2010

    The ONLY way we can hope to reclaim the clean waters on which a healthy global ecosystem depends is if we are fastidious in requiring all of us to take full responsibility for our pollution. This means that, when we purchase a computer, or a car, or generated electricity, the cost to US must include replacing the water in a pristine condition.

    This will, of course, require considerable cultural shift. However, this shift is already underway in the many “sustainable living” groups all over the country. If your organization can demonstrate real integrity (which unfortunately must be thoroughly proven by government and big biz these days), these groups can be your eyes and hands.

  17. March 21, 2010

    I live in a rural area of VA and one of the great water polluters here is sewage sludge, aka biosolids. Spreading this toxic substance on our farmlands creates problems with surface water, because the only buffer required is 50 feet with the biosolids applied to the surface and slopes of up to 15% allowed. But the main damage occurs silently to ground water. It may take years, but some of the constituents in sludge end up in the ground water beneath the site. There are other alternatives to this practice, the most promising being to use it for energy production. The need for EPA to address this issue is long overdue.

  18. March 20, 2010

    At present, there are well over 12000 NPDES pemits issued in the State of Missouri. A recent “sweep” at the Lake of the Ozarks revealed that over 25% of NPDES (or State Operating Permit) holders were in violation of permit conditions and, hence, in violation of the provisions of the federal Clean Water Act. By extrapolation, it is safe to assume that there are over 4000 NPDES permittees in the State of MO that are violating the CWA.

    A permitting program has three components: 1) Issuance of water quality protective permits 2) Monitoring to ensure compliance and 3) enforcement when compliance is not achieved (or ignored). At present, state agencies and EPA do a really good job of issuing permits, but a really lousy job of monitoring and enforcement. The best permit in the world means nothing if the holder doesn’t comply with permit conditions and if there if no enforcement.

  19. March 19, 2010


    We will be super brief, because we are not writing with either environmental or engineering expertise. We are field crop organic farmers, with over 500 member families in our “CSA” (community supported agriculture), who depend on us for their weekly shares of produce from June through February.

    We want to emphasize the need for EPA to GET AHEAD OF THE NATURAL GAS INDUSTRY. Please help us preserve our abundant clean water in the Finger Lakes of upstate New York, where currently 40% of our county is leased for natural gas drilling, by well-meaning but completely uninformed citizens. We understand, from research by Dr. Theo Colburn of The Endocrine Disruption Exchange, that there are very serious concerns with the technology now being used in the development of natural gas. A video of her work on this subject can be viewed at

    Also, “The Groundwater Protection Council” is a front group for the NG industry, as you probably already know.

    Thank you for hearing our concern,
    Gay Garrison, Chaw Chang and Lucy Garrison – “Full Plate CSA”
    Stick and Stone Farm & Three Swallows Farm
    Ithaca, NY

  20. March 19, 2010

    For over 20 years, the Lake Poinsett Sanitary District that serves the area around Lake Poinsett, SD, has been tasked in cleaning up effluent from entering the lake from inadequate or broken septic systems. Unfortunately our lake covers a large geographic area with fewer than 700 homes and businesses. The cost to complete our sanitary collection system is over $15 million adding 500 homes to the current 200 covered in the collection system. The need to complete the collection is great, but funding is not available and the cost is too great for the the 700 residents to add $15 million to pay for the completion. I’m sure many other districts are in the same condition and in need of funding. Do you forsee future grant money to complete these types of projects?

  21. March 19, 2010

    The Connecticut Federation of Lakes is very concerned that CT and the EPA are not helping with water quality problems caused by cultural euthrophication, storm water runoff and septic shortcomings. A recent national assessment report confirms this degradation of ponds and lakes. The state’s septic systems used by 35% of CT homes and businesses are not properly monitored. The MS4 stormwater regulations should be extended immediately to all towns. Alternative onsite septic systems need regulatory oversight. The CT Department of Public Health needs funding to write these regs. Decentralized wastewater management districts are a solution to best manage septic systems in sensitive lakeside areas. Easier, less expensive set up of these DWMDs must be forthcoming if positive results are expected.

  22. John permalink
    March 19, 2010

    The best protection for our watersheds is diversification. The adage of’don’t put all of your eggs in one basket’ holds true when it comes to land use. A healthy watershed is a diversed watershed. One sound reason why farms are evolving to the ‘mega-size’ operations is for fiscal survival. The federal policy in this country seems to be’bigger is better’. Not so when it comes to environmental sustainability and protection of our water. There seems to be too much regulation in the agricultural industry now that forces the hand of the small farmer into either going out of business or expand, in order to remain competitive. The small American farmer needs a federal stimulus packge for the protection of our local cummunities, local businesses and our local environment. The impetus that gave this great country of ours its strength and power is not its military – but its farmers! Without their sacrifices in providing each and everyone of us with cheap food and fiber, we would not have nor be where we are today. New York State has a voluntary process which has proven itself to be rewarding and successful in keeping farmers even more environmentally sensitive in their day-to-day operations: it is called the Agricultural Environmental Management process. The most limiting factor in making this process that much more successful is not having sufficent financial resources available to staff, plan and implement its recommendations. No need to pass new regulations for the inadequacy of underfunding a proven process. Give the American farmer the respect and support that they deserve, and they will prove to us even more of how ‘green’ they really are and have been, when it comes to our environment and water quality. I’d like to recommend that the federal policies allow for more indiviual state priorities to be adopted in meeting expected national goals & objectives. Local concerns may differ from county to county and from state to state; but they may be very important to have implemented and supported within the framework of a national policy. This recommendation emulates the role of our nations 300 plus Soil and Water Conservation Districts – delivering valuable, needed conservation on the land for improved water quality. Funding directly with SWCDs in implementing nonpoint sources of pollution control measures is an efficient method of delivering conservation.

  23. March 19, 2010

    There are a lot of great comments here. What if we start by pushing for the Clean Water Restoration Act? The passes of this amendment allows for easier regulation. Federal regulation is our best method for cleaning up and monitoring interstate waters. I apologize if I have repeated ideas previously mentioned.

  24. March 19, 2010

    Why don’t we hold a creative solutions contest and promote this contest among the citizens.

    Of course the contest is to get creative solutions to water problem.

    We can offer some monetary gains for the best and most practical solution.

  25. March 19, 2010

    My biggest concern right now is the damage to streams and rivers in Eastern KY and WVA from mountaintop removal of coal. To quote a study published in the Jan. 8 SCIENCE MAGAZINE, pp.148-149 “Mountaintop Mining Consequences”:
    “Burial of headwater streams by valley fills causes permanent loss of ecosystems that play critical roles in ecological processes such as nutrient cycling and producton of organic matter for downstream food webs.” The study also concludes that MTR mining increases SO4 concentrations and metal pollutants affecting streams. And more than 5-10% of a watershed’s area can suffer from lack of stream biodiversity and water quality.

    Please refer to this study. Thank you

  26. March 18, 2010

    I am outraged that the EPA does not require any soil testing or a summary of the fields used for manure application for fields not owned by the operator of a CAFO. “Distribution & Utilization” is a huge loophole that requires NO accountability for the millions of gallons and tons of contaminated waste being (over) applied to farm fields. Another extremely troubling procedure utilized by the EPA is allowing the CAFO operator to take manure samples from “unagitated” lagoons. How could this be considered representative of the manure applied to farm fields which has been agitated? According to the U.S. EPA, over-enrichment of waters by nutrients is the biggest overall source of impairment of the nation’s rivers, streams and lakes.
    Animal waste is now the main contributor in water pollution caused by agriculture in Ohio.
    Manure run-off has been linked to Lake Erie’s 6,300 square-mile “dead zone”, an oxygen-depleted area full of algae blooms caused by excess phosphorus where fish cannot live.
    Why would the EPA allow CAFOs to pollute our precious rivers and lakes?

  27. March 18, 2010

    Please take into account the confines of Proposition 218 within states like CA and MI and other states that have this. We cannot simply raise taxes of fees; we have to get a 2/3 majority vote to increase fees to raise money to pay for the added regulatory requirements. In other words, the State of CA does not have the money (actually the MS4s don’t have the money) for all these stormwater requirements like hydromodification or post-construction or new development/redevelopment retrofitting. So please consider this in your endeavors.

  28. March 18, 2010

    Watershed protection can begin at the source of potential pollution. All land-disturbing activities such as construction, mining, and landfills, should use storm water controls and have discharge plans. One source of pollution often overlooked is the track-out of dirt and debris from these sites that gets tracked-out on vehicle tires. Enormous amounts of debris, often contaminated with oils or toxins, are tracked onto public roadways everyday. This dirt and debris, when dry, becomes air born, thus contaminating air quality. During a rain event this dirt and debris gets washed into streams and rivers, affecting plant and animal life there. There are many other safety related issues associated with track-out, as well as matters of community relations. Many state and local authorities require tire washing equipment at these types of sites, but unfortunately, they don’t specify the how well the equipment has to work. Tire wash equipment should incorporate “Control and Contain” features so captured debris can be disposed of properly. Many sites are not required to have tire washing equipment at all. There are many other sites that contribute to track-out as well, such as coal burning power plants, ash dump sites, and steel recycling yards. The EPA should require more strict regulations to be put on these sites through state and local authorities such as DEQ. These regulations should include quality checks, records keeping, and enforcement policy. Millions of tons of contamination can be eliminated from the nation’s watershed by using qualified tire washing equipment.

  29. March 18, 2010

    One of my interestes and concerns is with drainage systems. As we improve our land drainage and move more water through various tiling systems chemicals do not have the opportunity of being filtered as well be before reaching our streams and rivers. have there ever been any studies regarding agricultural or small rural city and village systems? and if so what was the results?

    Water is a valuable resource and we need to carefully protect its quality.

    Interested comments appreciated.


  30. Mongo1967 permalink
    March 18, 2010

    If you truly were interested in improving water quality, the FIRST thing you should do is hold ALL companies and independent agencies to the same standard.
    I was visited by a storm water inspector a year [or so] ago and received a “write-up” [without fine, although I was threatened with a fine of $10,000.00+ per day] due to having pallets [clean, new wood] outside the building. The inspector noted that even though the were new, there is a potential for an oil or other polluting material to be present on the pallets [invisible to the naked eye] and this material could possibly travel across the parking lot [40’] to a storm water drain and it could possibly enter the storm water system.
    OK, I’ll buy that because I’m told to believe it by a government inspector or I’ll have to pay a fine.
    I walked him over to the 2 buildings next to ours, which drains into the SAME detention pond and pointed out the fact that one currently had stacks [roughly 200] pallets; which were old and used with what appeared to be an oil on them [which I cannot verify was oil], and the second building had stacks of automotive “racks” with paper and ruptured bags of Styrofoam “peanuts”; which were strewn across the parking lot.
    When I asked about their condition, he looked them up and informed me that they did not have a SWPPP, so they were beyond his inspection authority.

    Why, should I be held to a higher standard BECAUSE I did the right thing by obtaining a NPDES, and someone who is reckless with the environment get a “pass” on his responsibilities?

    Second, begin to tax those companies who send freighter [or other transporters] through the Great Lakes to help pay for the damage they have done and the damage they seem to not care about when they discharge their ballast into our waters. And believe me, it happens ALL the time. I really don’t care what anyone of them says. If they want to traverse our waters, they need to follow the rules and pay for the damages they have already done. We have far too many ocean-going freighters come through our waters and “dump” whatever they wish into our waters.
    Thirdly, give a tax break to those companies who are following the rules. Maintaining the environmental requirements does cost companies money. I am not saying we should allow companies to go tax-free, but there SHOULD be an incentive for companies to obey the laws of this nation. Otherwise, we will continue to have issues from companies who are just hiding what they are doing.
    Fourthly, when a company blatantly violates the laws of this nation, they NEED to have heavy fines levied against them. I keep reading about companies, which have been violating the laws for years and have been held-up in court cases, getting fines for something akin to a few thousand dollars. When they lose a court battle, the companies SHOULD be responsible for court fees and give them fines; which are [for example] 5 times the actual cost of the clean-up efforts. Our government considers themselves as “winners” to a court case when they fine a company $25,000.00 on a clean-up which cost the government [i.e., the American people] $100,000.00. To me that equates to a HUGE loss no matter how anyone tries to explain it. And to ensure that the company doesn’t roll-out the cost to their customers, the government should add a stipulation to the agreement stating that the company will not raise their rates [regardless of the services provided] for a period of time [e.g., 5 years.]
    OK, I’ll get off my “high-horse” now and continue to read the input of others.
    Thank You for listening…Mongo 1967

  31. H Kerfoot permalink
    March 18, 2010

    The practice of artificial recharge using sewage that has been treated to meet NPDES effluent criteria (“toilet-to-tap”) puts drinking water supplies at risk. Wastewater treatment is known to be an ineffective treatment process for numerous constituents commonly present in wastewater, such as MtBE, 1,4-dioxane, tetrahydrofuran, the hormones present in birth control pills, caffeine, and prescription drugs. Because the wastewater treatment process was not designed to remove these constituents, the assumption of its applicability is unscientific at best and places public water supplies at risk. In addition, carcinogenic disinfection byproducts (DBPs, above) are generated by the wastewater treatment process and are invariably present in chlorine-treated sewage effluents.

    To my knowledge, the EPA has not conducted studies on the persistence of these constituents in aquifers under site-specific geochemical conditions, so that there is no evidence of protection of public health from them. It is unscientific to just assume they will go away – That approach was used with ‘dry wells’ for disposal of used solvents and was the basis of the “sanitary landfill” approach as described in Life magazine and used at the Fresno Sanitary Landfill, which is now a Superfund Site.

    A lack of treatment or incomplete treatment of these constituents can result in low concentrations in treated effluents. An input of low concentrations in a closed system such as an aquifer that is recharged with treated sewage would result in increasing concentrations of these constituents and long-term exposure to low concentrations of them. Particularly for hormones and hormone-like substances, this represents a gamble that (a) there will be adequate time to develop technology for treatment or (b) aquifers will be converted to the equivalent of septic tanks and desalination of ocean water will be the source of drinking water.

    Based on EPA’s performance under the Clean Water Act, I do not expect this to have much effect on policy due to the political influence brought to bear by large (ground) water purveyors including semi-public entities and the EPA’s involvement in authorizing such practices without supporting data (since toxicological data and analytical methods with sufficient detection limits are not available.) When there is insufficient data to make a decision that could affect public health, the prudent thing for EPA to do would be to not authorize the practice until they could be satisfied public health and drinking water supplies are protected.

  32. March 18, 2010

    Banking Mitigation Policies need to be reviewed to focus on function losses.

    For my Master’s Thesis, I studied atrazine concentrations of surface and ground water sources in relationship to the proximity to permitted wetland destructions for Banking Mitigation. Sites with the greatest number of wetland losses experienced the highest atrazine concentrations.

    While Banking Mitigation attempts to stop wetland acreage losses, it needs to focus on the losses of wetland functions – not just acreage. We are learning more about wetlands every day and until we understand the complex make up of wetlands we will not be able to mitigate function losses.
    For example, wetland salinity affects the removal of atrazine. How many other characteristics are important to contaminant removal that have yet to be discovered?

    Wetlands, buffer strips, and natural grasses aid in alleviating non-point source pollution. These natural areas need to be preserved.

  33. March 18, 2010

    I think that a Public Service Anouncement campaign like was done in the 1960’s and 70′ such as the one with Iron Eyes Cody as an Indian seeing water polution would be great. As far as I know, the EPA has no central theme focusing attention on water issues. A national theme broadcast on TV, radio and billboards could be just the thing to get this important message out. It could be used in educating our young people who will be dealing with water issues in the future. I still get a tear in my eye when I see that old Indian paddling his canoe in all that poluted water. Just think what the “CLICK IT OR TICKET” slogan accomplished!

  34. March 18, 2010

    Thanks for taking comments. I’ve been practicing env’r law for over 30 years. In that time, I’ve watched the regulations grow but never shrink. I believe EPA has too many regulations to operate effectively.

    I suggest that you prune out 1/2 the rules, and replace them with general goal criteria rather than specific requirements about how to do things that may or may not reach the goal.

    Then neither you nor the regulated community have to waste time on rules that no longer matter, or that present niggling details that don’t amount to much. When everyone is able to focus on the IMPORTANT rules, then more compliance will be achieved and we’ll have a cleaner environment.

    Oh, and since you’re taking comments, one more specific to water. Please make sure that the TMDLs get done. After 30 years, most water bodies are still lacking, and that affects interstate waters.

    Thanks again. Respectfully, Robert Kellogg in Oklahoma

  35. March 18, 2010

    It is important to address water as one continuous medium – vernal pools,wetlands, inland waters, coastal waters, groundwater, and oceans. The current discussion on exempting some smaller water bodies from certain regulations is wrong-thinking and potentially harmlful.

    Development that impinges or builds on or near wetlands can have subtle but long-term effects on water flow, siltation, and flooding; hence water quality. Federal strength is needed to lead local jurisdictions to put environmental health in front of development needs or wants.

    Roadway runoff. Major issue.

    Enforcement, enforcement enforcement! Nothing speaks louder than money.

  36. March 18, 2010

    A solution to many of the polution problems associated with bodies of water is a very high flow rate (50+ gpm per square foot) water filtration system that uses air as a chemical in the form of 1.) a surfactant, 2.) a flocculant, and 3.) as a displacent. In addition this filtration system should be capable of effectively filtering and backwashing multiple forms of Zero-Valent Iron that is pre-fed upstream of the filter system.

    If the Zero-Valent Iron is pre-treated in such a way that it is more attracted to other contaminants than it is to itself it would be very beneficial. Since most Zero-Valent Iron particles are rather large in size, -325 mesh or 44 microns, it would be beneficial to develop anaerobic digestors so that bacteria such as Geobacter metallireducens could be fed “raw” iron and it could then convert this iron to magnetite particles in the process of its metabolism. These magnetite crystals would be smaller than 100 nanometers. This would increase the surface area of the iron exponentially. The magnetite could then be oxidized prior to pre-feeding upstream from the filter system.

    The iron after it is pre-fed into the system would then have opportunity to bond to, oxidize, or alter a long list of contaminants generally associated with the use of ZVI. In addition, because the iron has been treated in such a way that it is more attracted to things other than itself, it now will also seek out and attach itself to the media in the filter, thereby, creating a situation in the media bed similar to ion exchange media.

    Once this iron and filtered materials has loaded the media bed, it must now be backwashed in such a manner as to clean the filter media effectively so that the filtration process can begin anew.

    Once the filter is backwashed, the backwash water must be contained so that it may be further concentrated, to dry matter if necessary, for proper handling, reclamation, refining, or disposal.

    This filter system should be portable if necessary, and it should also be capable of being adapted to large scale uses, such as 1 million plus gpm flow rates for barge mounted applications. This system would also be capable of being built to handle small flows for use at the source of contamination.

    Experimentation has indicated that it is feasible to expect that a filter could soon be developed that would also act as a separator/filter for selective filtration. In other words if we could filter only the contaminants and leave the components that are part of the normal biology of the body of water, it would seem to be preferable to filtering the water of everything.

  37. March 17, 2010

    1) Major continental issues drive EPA’s policy, but the policy needs special revisions for the Pacific Islands, for example, TMDL works great for Lake Tahoe, but not for an island in the Pacific, it is not possible to model the receive waters to ascertain the threshold of “overloading” for some contaminants when there is not an enclosed body of receiving waters.
    2) Ocean disposal issues for New York Harbor are significantly different that for Pacific Islands, EPA has a self-proclaimed regional approach, but it is not truly local in substance, it is still driven by continental issues.
    3) EPA’s watershed planning guidance has one major and significant flaw, the omission of consideration and discussion related to existing drainage and flood control structures which are part not only of the urban/built environment, but also rural areas. Consequently, grassroot’s volunteer groups are misled and misinformed about the technical measures required to attain improved water qualilty in many of these existing urban/semi urban situations. EPA’s guidance needs revision to be truly “holistic” in approaching the discussion and solution of watershed issues.
    4) In the Pacific Islands a big problem has to do with WQCs (water quality certifications) which are related to USACE permits, local government agencies are very slow and often over-reaching for the smallest issues. I don’t think such responses are the intent of the congress. EPA needs to modify its guidance on WQCs so that many of these extremely small and insignificant projects do not get held up as they now do. Specifically, drainage or flood control project modifications in intermittent and ephemeral streams, bridge repairs, and things of such nature need less severe attention.

  38. March 17, 2010

    For starters- See our blog:

    We have been designing/ practicing “zero sewage” since the 70s.

  39. March 17, 2010

    I believe that the Clean Water Act and the Safe Drinking Water Act no longer serve the citizens of this country. Since we are dealing with the same water, recycled in different forms, we need a new, comprehensive SAFE WATER ACT to include the two previous acts and add to them protections from pollutants such as endocrine disrupter that are, at this time, not covered by any law.

  40. March 17, 2010

    …by “overflows” I primarily mean untreated discharges related to equipment failure, improper operation or design, and storm surges that cause overflow problems when storm water and sewage are mingled.

  41. March 17, 2010

    A high priority should be given to preventing overflows of raw sewage to natural waters from existing wastewater systems.

  42. March 17, 2010

    Watershed approach to addressing polluted runoff is theoretically a good idea. However, practically speaking, it does not work well. The problem is that there is no layer of government that has jurisdiction over watersheds. In Washington we have done scores of basin plans and only those that lie entirely in a single jurisdiction were implemented to even a modest degree. And even in those watersheds, implementation enthusiasm waxed and waned with elections.

    To make the watershed approach work, a governmental body must created with authority over the watershed to enforce NPDES permits and critical area law, to make land use approvals, and (with budget) to buy riparian zones and other sensitive areas that will not otherwise be protected.

  43. March 17, 2010

    Dear EPA,
    Pennsylvania offers a serious challenge to EPA’s very admirable efforts to restore our waters. Historically, endangered waters abound here. New challenges now make way for potentially even larger destruction. I can make my point very simply. Pennsylvania is “headquarters” for the Marcellus shale “gas rush.” Here in Bradford County (north central PA) we are experiencing a particularly heavy onslaught of gas industry activity. They use huge amounts of ‘clean’ water and create huge amounts of chemically contaminated and radioactive waste water (with no safe place to ‘dump’). For some unbelieveable reason, Congress made the industry EXEMPT (in 2005) from culpibility or responsibility for the destruction which their behavior creates! Amazingly, our DEP continues to issue permits. There are thousands of reports of poisoned water across the country. From western Pennsylvania to a small town in Wyoming County, there are cries for HELP from the people who have leased their land and who can no longer use or drink their contaminated water. In Bradford County there are reports of methane in tap water and water which ‘catches fire.’ Nowhere on national news is this being reported — even through this is not just a Pennsylvania story. There are numerous reports out of Wyoming, Texas, Colorado, Pennsylvania, etc. PLEASE TAKE A LOOK AT OUR SITUATION. We, for the most part, have no effective legal protection when and if our water systems are destroyed.

  44. March 17, 2010

    Although the wording ‘navigable waters’ is rather strange, the intent and goals of the Clean Water Act are clear. There however are three major problems, why neither of the goals will ever be achieved with our present EPA regulations:

    1. When EPA implemented the CWA, it used an essential test (BOD) incorrectly and as consequence ignored nitrogenous (urine and protein) waste in sewage, while this waste, besides exerting an oxygen demand also is a fertilizer for algae growth and thus contributes to eutrophication resulting in dead zones.
    2. By paying 85% for the construction of new secondary treatment facilities, many cities in the seventies designed and built treatment facilities with larger capacities than required and offered this over-capacity to local industries to treat their industrial wastewater, while this wastewater now contaminate the effluent or the excess sewage sludge with industrial contaminants.
    3. EPA’s earlier demand for disinfection of treated sewage (dropped in 1978) is still continued in many states, while many facilities still use chlorine to do so. This now has become a mayor source of chlorinated organics, some proven carcinogens or now called DBP (Disinfection By Products) found in open waters used for drinking water.

    Besides the fact that the faulty BOD test application still makes it impossible to evaluate the real treatment performance of a sewage treatment plant and what its effluent waste loadings are on receiving water bodies, EPA of the record in 1987 admitted that this test and the regulations should be corrected. EPA, at the same time also claimed that this would be impossible as it would require the re-education and re-tooling of an entire industry that is happy with the status quo. Who wouldn’t be, since nobody can be held accountable?

    If the EPA is really serious to clean up our open waters, it should first admit that mistakes have been made in the past, correct their testing procedures and finally demand best available sewage treatment. Much better sewage treatment is not only available, but can be accomplished at lower cost, all well documented by EPA’s own data.

  45. March 17, 2010

    here is a novel idea for the epa: why doesnt the epa prosecute all of those that they know have violated the clean water act with run-off or by pumping millions of gallons of effluent into the waterways, gulf of mexico and surrounding estuaries – like the city of marco island and its contractors?

    there are enough laws and regulations – enforce them instead of doing publicity about how concerned the epa is about the waters.

    epa’s own internal criminal investigators have written that the city of marco island violated the clean water act.

    can someone at the epa answer why 3+ years later there has been no prosecution?

  46. March 17, 2010

    The most significant problem we engineers face in designing storm water (SW) runoff projects that directly impact surface waters used for drinking water in the reduction of zinc and copper from the SW discharges to meet very low MCL levels.

    The EPA could aid in this very difficult task by funding University research to find innovative solutions that the EPA would approve for methods to treat for copper and zinc removals from SW runoff. Innovative would be a passive system that required a yearly or longer replacement of the treatment media.

    We are going nuts with regulators that are almost requiring chemical treatment systems with sludge removal, dewatering, and disposal.

    Please help find innovative solutions that local and state regulators will adopt for us to include in our designs.

  47. March 17, 2010

    Urban nonpoint pollution can be reduced if we focus on educating the public, change how we allow development to occur, provide funding, and regulate.

    Home owners, business owners, municipal decision-makers, need to learn about alternatives and their effectiveness. They need to learn how their actions (washing cars, raking leaves into the street, fertilizing the lawn, not disposing of pet waste, building large parking lots, dumping chemicals in storm drains, etc.) are contributing to polluted stormwater runoff. Reaching people and convincing them to change will take a longterm concerted and collaborative effort .

    * This effort will require longterm funding (10 years) for an effective outreach and media campaig.

    * Funding to help pay for large projects such as the redesign and replacement of a large parking or road that features low impact stormwater management.

    * Funding for municipal staff who will have to enforce the new regualtions.

    * funding to subsidize the cost of rain gardens, rain barrels, composters.

    We need more regulatory requirements. We will not reduce the pollution and improve water quality through voluntary actions alone.

    * Change the rules for new development and redevelopment, requiring low impact practices in urban, suburban and rural areas (more open space and rain gardens for infiltration), less impervious surfaces.

    * Set and enforce rules for buffers along waterways.

    * Regulate the use of lawn chemicals.

    * Locate illicit discharges and fine the pollutors.

    * and more.

    Nonprofit watershed groups, Cooperative Extension, municipal partners (stormwater engineers) and businesses are an ideal collaboration to lead such an effort.

  48. March 17, 2010

    Virtually all of the non-point source pollution derrives from current products and services purchased by consumers, therefore the solution will be found in changing consumer purchasing behavior through a private/public initiative. Rather than attempt to convince people that their desires and expectations are wrong, it is more productive to enable them to realize their objectives with different choices that do not increase total costs (up-front and operational). The following products and services are applicable to both existing and new residential and commercial developments.

    Water Use reduction options.
    1. Microirrigation of landscape beds (product)
    2. Soil Moisture sensors to minimize high and low volume irrigation (product)
    3. Increase soil organic matter (compost, mulch and biochar use) (product and service)

    Nutrient Reduction Options
    1. Slow release fertilizers (product)
    2. Compost topdressing utilizing blower trucks to overcome bulk transport and application barriers. (service)
    3. Soil amendment with biochar injected into the root zone (service)

    Pesticide Pollution Reduction Options
    1. Integrated Pest Management based Landscape Maintenance (service)
    2. No/Low Toxin Pest Control Products eg. soaps & Oils (product)
    3. Soil Amendment with Biochar to increase CEC (service & product)

    Stormwater Runoff Reduction Options
    1. Pervious Concrete and Asphalt (product)
    2. Disconnect impervious surfaces (service)
    3. Cistern (product)

    Stormwater System Pollutant Removal
    1. Floating islands (product)

    Government can create incentives through regulation and tax policy as well as Public Education through the Cooperative Extension to increase awareness of alternatives supported by sound science. This will create favorable conditions for marketing those alternative products and services by private enterprise.

  49. March 17, 2010

    Great to see public input on these topics.

    How is EPA selecting the “executives and thought leaders”?

    Are there plans for similar discussions on other water issues? These three are important, but certainly not exhaustive!

  50. March 17, 2010

    Auto repair shops adjacent to the Anacostia River/Anacostia watershed (Maryland)discharge auto related pollutants into the river.
    How can we create awareness to the businesses of runoff and the need to improve water quality?

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