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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. Suzanne Menges permalink
    March 31, 2010

    The answer is not more government regulation! The EPA is not able to fulfill its federally-mandated requirements as it is. A case in point: the currently-proposed “Clean Water Restoration Act” is disputing a single term in its wording: “Navigable”. Removal of that word could result in (conceivably) the monitoring of swimming pools and horse troughs. Ridiculous, of course, but could be used to make arbitrary decisions if in the wrong hands.

    In Arizona, our Department of Environmental Quality needs to remember that the support of local governmental agencies and community organizations made up of local citizens has always been the best approach, and has been successful in the past. All of the comments offered below have one thing in common-people are familiar with their local areas and their LOCAL issues. It IS possible to include multiple-use in the management of our rivers–including farming, ranching, fishing, and recreation. The answer is in local control, with effective land use and riparian management plans developed with all stakeholders involved.

  2. March 31, 2010

    In Maine, the largest source of pollution on our major rivers is far and away pulp and paper mills. We frequently hear from political leaders and regulators that point sources have been addressed and that now we have to worry about non-point sources. For big rivers in Maine, this is simply not true. Maine’s pulp and paper mills are generally poor performers compared to good mills in the US and especially in comparison to good mills in South America and Europe. Our Department of Environmental Protection is not willing to push Maine’s mills to improve their performance because of the political might of the paper industry.

    USEPA did not help the cause of Clean Water in Maine or throughout the US in the 1990s when it adopted Option A (requiring chlorine dioxide susbstitution for chlorine bleach) under the Cluster Rules rather than Option B (requiring oxygen delignification) which would have helped clean up our rivers and made our paper industry more competitive internationally. USEPA has also not been helpful in the permit battles over the Androscoggin River in Maine. This river still does not meet Clean Water Act standards nearly 40 years after the act was written. This is particualalry tragic because it was largely the problems with the Androscoggin River that inspired Senator Muskie to draft the Act.

    So, in short, we ask EPA for help. Help us clean up our large rivers in Maine by requiring our antiquated pulp and paper mills to modernize. This will benefit both our rivers and our pulp and paper industry.


    Nick Bennett
    Staff Scientist
    natural resources Council of Maine

  3. March 30, 2010

    On March 11, 2010, The New York Times published the first of a
    Toxic Water series concerning the worsening pollution in American
    waters and regulators. There was a listing by state with their
    locations on a provided map, which included inspection dates and
    number of violations for each site. Arkansas ranked third after
    Oklahoma and Colorado, with our Fayetteville water treatment
    facility and the city itself at the top of the 33 out of compliance
    in our immediate area.
    Our Fayetteville Council of Neighborhoods, which is made up of rep-
    resentatives from each city ward, is inviting the director of our water
    facility to discuss the issues at a future meeting.

  4. March 30, 2010

    Early in March the New York Times published a Toxic Water series,
    including a listing of all states with the total number of toxic water
    facilities, their location on an available map, inspection dates and
    number of violations for each. Arkansas ranked third after Oklahoma
    and Colorado, with our Fayetteville water treatment facility and the
    city itself at the head of the 33 listed violators in our area.
    Our Fayeteville Council of Neighborhoods will be asking the director
    of our water facility to discuss the concerns at a future meeting.

  5. March 30, 2010

    In order to create an ecologically sustainable world it is imperative that the EPA work with others in government to provide proper incentives for keeping our land, air, and water clean.
    Georgist economists believe that a good way to do this is through the Green Tax Shift. This entails a reduction of taxation on things we want like jobs and capital investment while placing user fees on the destruction of our environment.
    We should see the natural environment as our collective commons. As such society needs to charge a user fee on the extraction of natural resources and the pollution of our land, air, and water. Thus, instead of relying solely on regulation we need to more fully implement the principle of charging user fees on waste and removing taxes on work.
    For more information see:

  6. March 30, 2010

    I think EPA should increase focus more of their WQ Monitoring resources to support States in developing Aquatic Life Use biological assessment biocriteria There are tremendous differences between State biological assessment programs to the point where data comparisons and water quality assessments are often not possible on a regional level or even in the same watersheds crossing interstate boundaries. Relative to human health problems and discharge regulation, EPA has given little attention to improving aquatic life conditions or development of consistent biological assessment protocols that are applicable from state to state or compatible with many current state bioassessment programs.

    The biological condition of local water bodies is important to the public and is most often the basis by which to evaluate impairments, a watershed’s attainment potential, restoration progress, effectiveness of BMPs, TMDL needs, and important water manager planning decisions. Several States are developing stronger biological assessment applications and biological measures while many others are not. EPA should increase emphasis, support, WQ monitoring funding and encouragement to states to develop and/or improve their biological assessment programs with such tools as the Tiered Aquatic Life/ Biological Condition Gradient process and similar resources. Such biological assessment improvements would allow for better biological condition evaluations cross state boundaries, in a regional context, and closer to supporting a meaningful water quality assessment on a National scale.

  7. March 30, 2010

    The Resource Conservation District of Santa Cruz County (RCDSCC) has served its local community since its inception in 1941 over an area of 260,000 acres, and since that time the RCDSCC has gained local and statewide recognition for conservation work with urban, rural and agricultural communities.

    As a local non-regulatory organization, the RCDSCC has credibility with private landowners and a multitude of existing working relationships solving resource conservation problems. A long standing relationship established by an MOU, exists with the USDA NRCS, who have provided technical oversight in soil and water conservation to the RCDSCC since 1935.

    Examples of successful projects the RCDSCC has implemented in the recent past include:(1) The Partners in Restoration Permit Coordination Program, the first countywide permit coordination program developed in California, (2) Ramsey Park, a 30 acre wetland restoration project in Upper Watsonville Slough Complex, (3) Beach Road, an agricultural water quality demonstration project of erosion control that extended over 5 miles and worked with multiple landowners, and (4) Bioswales, an innovative demonstration project that used contoured swales to balance production, habitat preservation and ground water infiltration.

    The RCDSCC has provided the following suggestions regarding what EPA can do to achieve healthy watersheds and sustainable communities.

    *Continue actions that support reduction from urban and agricultural non-point source pollution, such as education, funding, regulatory action, and permit coordination with agencies.

    *Support and fund research of management measures supported by science. Educate about BMP alternatives

    *EPA should support innovative products and services by providing incentives and adapting policy for such products and services (e.g. Soil moisture probes, Integrated Pest Management, LIDs, etc.)

    *Long-term funding to not only implement projects, but also monitor and analyze project success.

    *Funding for agency staff. By not having sufficient financial resources available to staff, they cannot plan and implement regulations and recommendations. It is not the current regulations that are insufficient, but the lack of funding of these regulations.

    *Coordinate with state and local agencies nonprofit watershed groups, Cooperative Extension to improve coordination across watersheds, so that a watershed approach is possible, and to lead this process. (Provide a web-based forum that highlights examples of functioning watershed partnerships throughout the country.)

    *Fund local conservation districts in implementing nonpoint sources of pollution control measures, as this is a proven and efficient method of delivering conservation on the ground.

    *EPA’s planning guidance should be amended to include a discussion related to existing drainage and flood control structures in urban and rural areas.

    *EPA needs to modify its guidance on water quality certifications as related to USACE permits so that many of the smaller projects do not get delayed in permitting, and as a result never reach implementation.

    *Put more resources into the completion and execution of TMDLs

    *Employ a mass public service announcement campaign to educate on water quality and pollution

    *Please take into account the confines of Proposition 218 within states like CA that cannot simply raise taxes of fees; these states have to get a 2/3 majority vote to increase fees to raise money to pay for the added regulatory requirements (i.e. stormwater requirements like hydromodification or post-construction or new development/redevelopment retrofitting).

    *Support underserved communities including small farmers, non-English speaking farmers, organic farmers, specialty crops, with federal stimulus packages and tax breaks for the protection of our local communities, local businesses and our local environment.

    *Support implementation of Best Management Practices through cost-share assistance, funding for follow-up monitoring, and extended funding timelines that will provide enough time to see effects.

    Thank you for this opportunity to comment.

    Karen Christensen
    Executive Director
    Resource Conservation District of Santa Cruz County

  8. March 30, 2010

    I can’t count how many times while fueling my vehicle during a rain event at a local gas station I have seen a sheen of petrolieum making its way to a catch basin. I believe extending the Industrial Storm Water permit requirements to all fueling facilities and requiring BMPs such as berms around fueling areas would effect a significant water quality improvement.

  9. March 29, 2010

    A key step toward protecting and improving our watersheds is to break down the regulatory silos and leverage the programmatic and legal tools available to protect our nation’s watersheds. Recognizing that the quality of our watersheds includes protecting our source waters for public health as well as for swimming and fishing should be a component of every water quality discussion.

    For example, Administrator Jackson’s recent announcement that EPA would use the authority of multiple statutes to help protect drinking water ( could also be used to leverage water quality goals and protect our watersheds.

    Several years ago, EPA’s Assistant Administrator for Water said,

    “Protecting public health under the Clear Water Act (CWA) is a critical element of our mission. To protect a public water supply use, we must protect the ambient water quality upstream of each water intake. Reliance solely on drinking water treatment, beyond that which is needed to address naturally occurring pollutant concentrations imposes an unfair burden on communities to address preventable problems caused by man-made sources of pollution.”

    AMWA strongly encourages EPA to work to use the CWA as a tool to protect drinking water sources. To achieve this, EPA’s various program offices and regional offices responsible for CWA implementation must work together.

    Currently, the CWA does not provide an effective incentive for upstream non-point dischargers to accept responsibility for their discharges and meaningfully support source water protection. This is unfortunate as contaminants can often be controlled more effectively and more economically at their point of generation rather than at the “end of the pipe.”

  10. March 29, 2010

    I was not commenting on anything stated in your e-mail.

  11. March 29, 2010

    I make reference to a short artice on page 14 of Discover Magazine, April 2010. It shows that beavers could be used to dam streams. This would reduce water runoff. It would be more likely that the streams during smmertime conditions would not be dry. This is based on work done in Washington State. From a study made at Elk Island National Park in Canada, wetlands would be holding more water when beavers were present.

  12. March 29, 2010

    Sorry – my reply above should have said that these five factory farms will produce over 100 MILLION gallons of untreated waste each year.

  13. March 29, 2010

    I live in Wood County Ohio which has seen an influx of dairy factory farms. If all the proposed operations are built, these five CAFOs would have almost 10,000 cows within a 7-mile radius and would produce over 100 gallons of untrested liquid waste each year.
    Our county lies in the former Great Black Swamp and is aggressively tiled. Although Lake Erie is once again full of algae due to excess phosphorus, our legislators and officials continue to ignore this 800 lb. gorrilla in the room.

    • 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.

    Manure spills, leaking lagoons and the over-application of manure are major threats to the purity of our streams, rivers and ground water. Please enforce the regulations and force all the CAFOs to apply manure at AGRONOMIC rates. Big Ag has made a mockery of the Clean Water Act.

  14. March 29, 2010

    I live and work in a watershed that is forested, has a rural base, and the WQ issues are almost all non point source. Almost all of our resource conservation management has been collaboratively designed on a consensus-based roundtable setting with wide representation of stakeholder groups. We have accomplished far more than I would have thought possible, including winning the Theiss International Riverprize in ’04, and completing a very long list of conservation improvements for WQ and aquatic health. However, when we dump up against the political arms of agencies responsible for water quality assessment and improvement we run into stone walls such as described in the example below:
    If we have five pounds of lead to get rid of, we’d be violating federal and state laws if we just threw it over the back fence and it rolled into the creek.
    The EPA was called and asked about this situation.
    They said “you can’t do that, you are violating laws; the Clean Water Act antidegradation provisions, and the Endangered Species Act laws”.
    NOAA Fisheries said that: we’d be “risking prosecution for an ESA ‘taking’ by violating pollution laws.”
    I called Oregon Dept. of Environmental Quality and the Dept. of Fish and Wildlife (ODFW) and I asked; if it would be good enough if I cut the lead up into small pieces and then threw them back into the creek. They said, “ You could be heavily fined if that was done.”
    “If I tie a string to each piece and then throw it back out, would it be OK?” “ Of course not,” they replied.
    “If I tie a hook to each string and throw it out into the stream, until it breaks, can I avoid all of those laws and fines?”
    ODFW said; “Uh oh, I wouldn’t touch that with a ten foot pole!”
    Lead, from fishing sinkers lost in low calcium waters becomes bioavailable in many western Oregon low-calcium streams and is toxic to fish and other aquatic organisms. Alternative sinkers that are not toxic are available. Lead sinkers in low-hardness waters demonstrably violate the intent of antidegradation provisions of the Clean Water Act.
    The intent of the CWA Antidegradation provisions is violated (if not the State of Oregon interpretation and Standard). State of Oregon Antidegradation provisions apparently do not cover Non Point Source pollution. Why not? If the other Standards are supposed to adequately cover NPS waters, why can we keep adding more lost fishing sinkers that are dissolving and degrading the water quality in low calcium systems? How can we allow degrading railroad bridges to add huge quantities of lead-based paint chips and toxic metal leach water to our mid coast salmon streams.

    “There is no threshold below which lead remains without effect on the central nervous system”.
    (Brain Research 1998 Jul;27 (2):168-76).

    “Fish brain lead levels tend to reach equivalent concentrations to the dissolved lead water levels fairly quickly” (Dan Weber, personal communication).

    There ought to be a law!
    Oh, there is, I guess.

  15. March 29, 2010


    Canandaigua Lake is surface water source for drinking water for five (5)-municipalities for over 65,000 peorple.

    What has worked?

    Canandaigua Lake has a set of Watershed Rules and Regulatins (Rules & Regs) that are embedded in the New York State Public Health Law (NYSPHL), which charges and empowers the Canandaigua Lake Watershed Commission (CLWC) to enforce the Canandaigua Lake Watershed Rules and Regulations. The CLWC is an organization of the five municipAalities that draw water from Canandaigua Lake, treat it, and sell it to their residents and to other communities. These minicipalities are:

    City of Canandaigua
    Town of Gorham
    Vilages of Rushville, Newark and Palmyra

    As the Canandaigua Lake Watershed Inspector, my duties are to enforce these Rules & Regs to include patrolling and inspecting for sources of point and non-point pollution, investigating complaints, serving violation notices and seeking correction or mitigation. Since Canandaigua Lake does not have puplic sewers around the entire perimeter / shore line, onsite wastewater treatment (septic) systems are my priority. I work directly with property owners, municipalities, and code enforcement officers`with the review of plans and the inspection of the installation of all onsite wastewater treatment systems to ensure compliance with current New York State Department of Health (NYSDOH) and New York State Department of Environmental Conservation (NYSDEC) requirements. I also work with the consulting engioneers thruogh the design process of innovative designs for systems on difficult sites. Funding for this Inspection Program is obtained through water rates.

    What has worked?

    Implementation of our “Comprehensive Watershed Management Plan”. In 1994 concerned citizens along with variuos county agaencies developed a comprehensive inventory of current conditions of the watershed, potential souces of pollution, along with nearly 100 recommendations to protect the watershed. In 1995, the fourteen (14)-muncicipalites that lie within the Canandaigua Lake Watershed came together to weigh each of the recommendations. After stringent review, 80 recommendations were endorsed, which formed the foundation for the Watershed Management Plan. After careful consideration, all fourteen (14)-municipalities formed the Canandaigua Lake Watershed Council, and made the decision to adopt, fund, and implement the Watershed Management Plan. The five (5)-maim segments of the plan are:

    1. Implementation of 80 Endorsed actions
    2. Sampling and testing program
    3. Agricultural “Best Management Practices”
    4. Onsite Wastewater Treatment (septic) System Inspections
    5. Capital Improvement Projects

    The plan provides, in specific detail, on how, and where the 80 endorsed actions will be implemented. Thes actions are focused on reducing pollution from variuos sources, ranging from:

    * pesticide use * forestry
    * mined lands * recreation
    * development * chemical storage
    * Hazardous spills * onsite wastwater treatment (septic)

    The plan incorporates or includes, as a very significant part of the Plan, The Canandaigua Lake Watershed Inspection Proram, as described above.

    Funding for implementing the rest of the actions comes from the fourteen (14)-municipalities through the Watershed Council, grants and our lake organization partners. Notice, I said “Partners”.

    Now,—What doesn’twork?

    Again, notice I said “Partners. None of what I described above could have been accomplished without public / citizen buy in. Continual education through workshops, forums, seminars, etc. held locally, keep the public informed of how certain types of land use activities have the potential to pollute the lake. Informed citizens are more cooperative in participating and funding when they understand the ramifications if thay don’t. Without public buy in, citizens regard regulations or restrictions on what they can and cannot do on their property as “Big Brother” telling them what they can and cannot not do on their property. This public education has to be continual, as there are always new people moving into the wateshed.

    How can we protect & improve watershed given the challenges of various sources of pollution?

    By implementing comprehensive watershed mamagement plans as described above. Local gaencies such as Soil & Water Conservation Districts, Cooperqtive Extensions, Health Depatments etc. should form task forces to include citizens / citizen organizations to inventory the current condition of their watershed and potential sources of pollutuion with the expressed purpose of formulating a “Watershed Magaement Plan”, again as described .

    What examples of effective practivces and strategies can be “scaled up” to State and National levelss for greater effectiveness and brader use?

    Again, it is the implementation of comprehensive “Watershed Management Plans”. To scale them up to State and National (EPA) levels, grants for environmental projects to protect watersweds, should be tied to Watershed Management Plans. Issuance of grants should be given priority to watersheds that have a comprhensive Watershed Management Plan that the watershed is implementing. This assures the State or National agency issuing the grant, that the money is being spent wisely since the project is linked to the implementation of an action of the Plan. Prioritizing grants in this manner would encourage other watersheds to create Watershed Management Plans. Also grants should be based on matching local funding or in-kind contribution to the project by the watershed. For example, many of our projects are installed by local Town and County Highway Departments of the municipalities in the watershed. We look mat thia win-win stiuation for all.

  16. March 29, 2010

    I am James Hazlitt of Hector, NY. I have owned and operated our 85 acre vineyard on the shores of Seneca Lake since 1960. All three topics are of top concern to us. To address these topics we do the following:
    1. diversion terraces across our farm between NYS Rte 414 and Seneca Lake.
    2. Mulching vineyard row centers with round hay bales.
    3. Mowing vineyard row centers rather than clean cultivation.
    4. Permanent sod on vineyard head lands and road ditches.
    5. Using foliar fertilizer rather than spreading on ground.
    We try to use the most environmentally friendly fungicides, herbicides, and pesticides. We have constructed a spray pad for mixing and containing spray chemicals. We received the AEM award for Schuyler County in 2009.
    I am also the treasurer of the Schuyler County Soil & Water Conservation District as my father was before me.

    We live on Seneca Lake and I am appalled by the stormwater runoff of the larger streams which turn large portions of our lake brown. This is caused by our county and Chemung County’s highway departments road ditch management practices. They love to clean road ditches in the winter when grass seed won’t grow. You can better protect the health of our waters by making a law that road ditches may not be cleaned or constructed between October and April. When cleaned or constructed between May and September road ditches must be seeded and mulched.
    One last comment – gas drilling should not be allowed closer than two miles from a lake or river.
    Respectfully submitted,
    James R Hazlitt

  17. March 28, 2010

    RIGHT NOW the state of Texas is in the process of granting ALL 50 states the rights to dump THEIR radioactive waste in Texas, with some dump locations on top of four (4) major water sources.

    The proper health and safety measures have not been taken to accept this waste.

    •RIGHT NOW we do not know the impact that this additional waste will have on the surrounding area.
    •RIGHT NOW a transportation study has not been completed.
    •RIGHT NOW a wide variety of government maps show that this radioactive waste site is directly over the Ogallala and 3 other aquifers.
    •RIGHT NOW the Texas Low Level Radioactive Waste Disposal Compact Commission (Compact Commission) does not currently have the funding in place to oversee and the importation of such dangerous waste coming in from so many different sources.
    •RIGHT NOW an independent and comprehensive environmental impact statement has not been submitted.

    •No radioactive waste stream outside of Vermont has been evaluated. Texas cannot afford the liability of accepting this waste and then having them decide, after the fact, if it is safe Texas. Studies and evaluations need to be done before the waste is imported into our state.
    •A privately held company wants the toxic waste evaluated after it is received, but the State of Texas, not the owners of this company, will be fully liable for damages that could be inflicted upon the public. Therefore the Compact should not be expanded until this issue is resolved.
    •A current and independent Environmental Impact Study has not been conducted. The last study was eight years ago and is obsolete. More waste should not be accepted in the absence of a full blown environmental impact study.
    •A Transportation Safety Study has never been completed. How can we possibly accept more waste into the state of Texas without a full-blown Transportation Safety Study? The Compact should not be expanded until a complete transportation safety study has been completed and submitted for approval.
    •No adequate provisions have been made for the co-mingling of waste. Where are the rules to prevent waste going out of Texas to another state, co-mingled with unknown waste, and then returned to Texas under a different name? The compact should not consider expansion until this issue has been resolved.
    •Many government maps show the waste site is directly over the Ogallala aquifer. No sources dispute the fact that other aquifers are also underneath the site. A government specialist has reported that there is a water table only 14 feet below the stored waste. The Compact should not be expanded until an independent study has determined the exact location of the Ogallala and other aquifers under the radioactive dump site.

  18. March 26, 2010

    Industrial activities need to take a back seat when water policies and usage is determined. The nation needs a new paradigm that puts the safety and health of the watersheds and aquifers first in line. The solution to pollution can no longer be dilution- industries and people must learn to develop new ways of doing business with less impact on fresh the water supply both coming in and going out. The EPA must draft new legislation that speaks to these issues and makes the primary goal of the agency to set the bar high enough so that both people and industry will think twice before making the assumption that drinking water is a plentiful commodity. Enforcement and fines have to be developed in a way to make them not “a cost of doing business” but rather a severe penalty for those that are too cavalier about the need to protect our Nation’s fresh water resources.

  19. March 26, 2010

    I live in a very rural area. The farming community in my area cause many problems to our waters, from soil run off to land applying animal waste. All of it flows into the White River. Very few farmers have filter strips around their fields. Most farm right up to the drainage ditches and their crops even fall into those ditches. That alone is great cause for concern besides the chemicals that they use. Already, before the grass was even growing this year, there were algae in the ditches from land applying turkey manure. I feel very little attention is paid to the farming industry and believe that we could clean our waters up greatly by making sure better farming practices were in place.

  20. March 26, 2010

    Ten years ago I was invited to participate in a program to prevent storm water t pollution.

    Take a look at an alternative management practice and metrics to insure that this happens.

    key word:
    colson, cameron
    Hydromechanical Obliteration

  21. March 26, 2010

    Nature has a wonderful way of correcting it’s problems. If you would allow it to work, it will lower government expense and larger benefit would be received. Dikes, levies, and other water flow devices are contrary to the natural order. When Mankind are foolish enough to live below sea level or below flood level, move man, not the world.
    Farmers wish to grow crops. Every private farmer I have ever met has tried to prevent erosion and nutrient loss. Protecting the soil and water is a farmers life. Please do not add additional restrictions on good and natural soils management, it will only add cost, and only the corporate farms will be able to shove the cost of this regulatory beast on to the consumers.

  22. March 25, 2010

    Stop ripping out perfectly good concrete and installing pavers. Polymeric sand and sealers are used to seal the pavers sand from washing out!

    In the longer term pavers become infested with weeds and moss. Slip and trip hazard logic must be out of style.

    San Jose and other cities spray these weeds in the cracks with weed killers. Weed killers not only kill the weed but the residue of the dead weed is still there along with what ever did not evaporate.

  23. Bryan Replogle permalink
    March 25, 2010

    It seems to me the EPA is rather toothless when it comes to enforcing regulations. Big industrial polluters and wasters of water are somehow allowed to continue polluting and wasting water, despite the existence of the EPA and environmental protection laws. I say give the EPA the power it needs to put an end to these abuses and hold violators accountable – regardless of how wealthy and politically connected they may be.

  24. March 25, 2010

    Something that is largely ignored is the dumping of garbage into the rivers, oceans and gulfs. Not only does it add large quantities of plasticsthat does not break down, but it adds billions of tons of organic matter that as it breaks down it destroy the natural habitat. Indigenious plants and animals cannot survive in the dumping areas. Cities like New York still dump barges of garbage every day. The US needs to ban dumping of any garbage to any water sources, including the oceans with no mileage limitation from shore.

  25. March 25, 2010

    Clean water is extremely valuable, polluted water is extremely costly. If we were to understand the long term economics accurately, it would become obvious that the ecosystem services provided through aquatic health are not just desirable but essential, and that pointedly investigative water quality monitoring is almost always well worth the money needed to get it done. Most needed WQ assessment for the toxics parameter are not done due to some assumption that testing is too costly. This is short term thinking that does not understand the cost/benefit of ecosystem services other than short term. We need to get our heads out of the sand, and fund far more pointedly investigative monitoring if we are to be able to improve environmental health in time.

  26. March 25, 2010

    The #1 pollutant in most watersheds is agricultural discharges. Collaborative approaches have not been effective (e.g. Chesapeake, Klamath, Bay-Delta). We need to invest in PROHIBITIONS and ENFORCEMENT…no more “stakeholder” groups – This is about the PUBLIC INTEREST and THE PUBLIC TRUST. Previous administrations have too often ignored the Public Interest and compromised the Public Trust. We’ll judge this administration on how well it performs on these two key criteria.

  27. 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.

  28. March 24, 2010

    Contrary to assurances of EPA, state officials and the waste industry, state and federal sludge laws do not protect surface and ground waters from pollution caused by land-applied sludge. Sludge problems in New Hampshire:

    A few years ago, engineers for the sludge company BFI reported that industrial solvents acetone and 2-butanone were found in groundwater in Loudon, Tamworth and Pelham, NH, which had leached from paper mill sludge stockpiles in gravel pits.

    After sludge was spread in a Sandown, NH gravel pit, toluene, acetone, 2-butanone and 4-isopropyltoluene were found in well water of an abutter. Tests on file at NH Dept of Environmental Services reveal the same chemicals were in the sludge which had been spread in the gravel pit.

    Research by UNH Professor William McDowell on sludge spreading in a Hooksett, NH, gravel pit found: “Results suggest this level of nitrogen application, even with the C:N (carbon to nitrogen) adjustment, has negative impacts on groundwater quality.”

    Earlier UNH research by Catricala, et al, on sludge in sandpits found that sodium levels in groundwater were 18 times EPA allowable drinking water levels, and nitrates were 10 times allowable levels. Cadmium also exceeded drinking water standards.

    A few years ago, sludge spreading at the Kings gravel pit in Hooksett had to be suspended when pollutants, including nitrates and manganese, contaminated nearby residential wells on Goonan Road. The sludge company first provided residents with bottled water. Later, when they sold the pit for development, the sludge company was required by the buyer to connect the Goonan Road residents to City of Manchester municipal water so no sludge risks or liability would be passed on to the new owner. The sludge company also required residents to sign releases of liability for adverse health effects they may suffer in the future from the contaminated water.

    In Maine, the Dept. of Environmental Protection (DEP) permitted the dumping of a combination of ash, papermill sludge, sewage sludge, commercial fertilizer and bioash to “fill and revegetate” a spent gravel pit over an aquifer in East Sangerville. Neighbors started having problems with their wells, including high lead levels. They suffered memory and cognitive problems, muscle and sleep disorders, and mercury and lead in their urine.
    May 2009: “Because the DEP approved the gravel pit applications without comment from town officials, residents were concerned about the DEP’s doing the most recent testing. They asked that an independent firm also test the groundwater samples.”

    Federal sludge laws clearly state communities can enact local sludge rules more stringent than federal rules. But the cowardly, duplicitous EPA sides with state and waste industry sludge bullies who sue rural communities to overturn their local sludge rules. EPA needs to step up and support local sludge rules, as its own laws provide.

    Helane Shields, Alton, NH

  29. March 24, 2010

    As a construction site SWPPP inspector, I can attest that enforcement is almost non-existent in our area. We have inspected 100+ different sites over the past 6 years and have only seen an EPA inspection once in all that time. That is good for me since dealing with an EPA inspection can be burdensome, but it sure isn’t good for the water systems. What I learned from that 1 EPA inspection is that many construction sites within 5 miles of it spent some resources getting thier sites up to compliance out of fear that they would be next. That lasted a little while but wared off over time. I would bet that if the EPA did 20 inspections per year (continually without breaks) in our city, that would be enough to keep 200 sites in order, or at least improve it. But, the economy is also taking it’s toll on many of the developers of these constructions sites. Many are home subdivisions with lacking lot sales.

  30. March 24, 2010

    Topic 1: The Watershed Approach

    • If you have experience with protecting watersheds, what has worked and what hasn’t?

    Response: I fence my livestock out of all waterways including smaller streams and creeks as well as the larger streams. The filtering effect of significant grass buffer zones keeps livestock manure and urine from entering the water bodies. Maintaining appropriately sized grass buffer zones is the least expensive and most effect means of keeping ground contaminants of all kinds out of our water bodies. I do this voluntarily because I care about the well-known negative downstream effects of farm pollutants. Unfortunately, a drive through any rural area of the United States containing creeks and streams quickly demonstrates the vast majority of American producers do not voluntarily adhere to this simple practice. When voluntary programs don’t work – and we’ve plainly demonstrated they don’t – then enforcement is the most logical step. The first tier of enforcement should begin with the same approach used in the farm programs taken to prevent drainage of wetlands – subsidy payments are re-claimed by the Government and appropriate fines are extracted. Further enforcement need only to follow the current laws on the books.
    Additionally, voluntary proper use of liquid manure systems simply does not currently exist for the vast majority of livestock operations using them. Liquid manure systems are a “cheap” way to reduce labor while disposing of excess nitrogen into the air and water. Again, a simple drive in the country illustrates the point better than words. Obviously an immediate banning of liquid manure systems will not happen. Therefore, a phase-out approach is necessary beginning with the mandatory requirement to cover all open liquid manure storages of All sizes on All operations (not just CAFOs and CFOs). Couple this with the requirement that All liquid manure on operations of All sizes be properly injected into the soil in a fashion that does not allow escape to the waterways or to the atmosphere. The few farmers who currently practice these methods voluntarily do it either because they have a true concern for the environment and people, or because they learned that over 90% of the nitrogen value of liquid manure is lost through conventional surface slathering application techniques and uncovered storages. A final phase would be to simply outlaw liquid manure systems beginning with those operations with any history of violations.
    Solid manure storage has some problems as well, and need to be addressed through proper storage and application techniques, but the most urgent attention should be focused on liquid manures.

    • How can we protect and improve watersheds given the challenges of various sources of pollution?

    Response: Require that the generators of the various pollutants (not the taxpayers) be responsible for preventing the pollutants from leaving their possession. Technologies exist to prevent disposal of all toxins into the environment. Begin with aggressive enforcement of current laws. In any case, all polluting substances, i.e. agricultural, industrial, and residential wastes, chemicals, solids etc. must simply be prevented from entering the waterways. As stated above, appropriately sized grass buffer zones are the most effective, least cost method for eliminating land surface applied sources of pollutants (including excess fertilizers). Eventually, however, the land owner must be responsible, not the Government, for maintaining the buffer. It appears heavy fines are the most effective means of creating the proper sense of urgent responsibility.

    • What examples of effective practices and strategies can be “scaled up” to State and national levels for greater effectiveness and broader use?

    Response: The NRCS currently promotes grass buffer zones. Scaling is not really necessary; simply apply the techniques. National standards for set-backs on surface applied wastes should be established and enforced. If the EPA wants to entertain promoting manure digesters as a means of reducing the toxicity of liquid manures during the interim phase out, then I suggest EPA look to the examples set by the Government of India beginning in the late 1940s when Gandhi promoted the use of small scale manure digesters as a means of encouraging rural habitants to generate their own on-farm cooking gas. While many of our current “experts” discourage us at the seminars by claiming that methane digestion is only feasible at the 1000+ cow level, India has successfully captured methane from the manure of a few as 5 cows to provide sufficient cooking gas supplies for a family. Our Government needs to put more of the research dollars into thinking out of the large scale industrial box.

  31. March 24, 2010

    The way enforcement of water regulations is conducted today is driven significantly by EPA’s means of measuring state enforcement performance. This looks almost exclusively at large point sources of pollution that have been known and regulated for decades. Unless or until EPA begins to evaluate state performance on a broader scope of topics and data, nothing will change in the ability to address problems holistically, on a watershed basis or involving the now dominant contributors to pollution – the multitudes of non-point sources.

    Many other comments have noted that voluntary actions will not get us where we need to go. But the added regulation that will be needed cannot be matched with more resources to enforce them, especially since this is done almost entirely at the state level. This means EPA must not only allow a careful and deliberate divestiture of resources away from the major point sources, but it must lead in doing so. This does not equate to abandoning the focus on these sources, but means recognizing their falling relative importance and seeking more efficient ways to keep them on track.

    In this shift, EPA will also have to abandon certain costly approaches and perceptions of needs related to data. An insistence by EPA on ownership and possession of bewildering levels of detail in its own data systems while states conduct the vast majority of work, has so far produced largely failed and unreliable sets of EPA-owned data. EPA rejects that its data is flawed to the point of failure, but note the New York Times series of articles “Toxic Waters”, especially one entitled “Clean Water Laws Are Neglected, at a Cost in Suffering” which relies on point source enforcement data for its premise. Most importantly note the state responses to the data questions posted here: .

    EPA’s solution to poor data in this case has been to cajole and badger states into a greater effort on data. The problem is not effort, but design of systems employed and the dwindling lack of value in much of the information of focus. This approach cannot be carried forward to the management of innumerable non-point sources that would multiply the data burden 100 fold with questionable benefit to the environment. The limited value in the current data could be preserved in a scaled back approach commensurate with its contribution to resolving our ongoing and new water problems.

    On a hopeful note, what is advocated here for data is exactly what EPA has done on other fronts, for example in the realm of sharing important ambient data on air and water quality as well as emissions data. In these cases, a more efficient network-based sharing model is employed to supply standards-based data. This enables all participants to pull directly from the network without the need to have each participant (even EPA) maintain a full copy of all the data on its own. This avoids the problem, described repeatedly by states, of keeping multiple copies of the same information all synchronized and up to date.

  32. March 24, 2010

    Lawns and landscaping create a great deal of pollution. A re-thinking of our use of landscaping could reduce pollution and create jobs for people doing the conversions. A key aspect of such change over to more water and resource efficient landscaping will be the training of the people maintaining the grounds.

  33. March 24, 2010

    Economics is a big factor in how people act.
    A commodity may be made more expensive through regulation but it is so much better to create savings through changes in efficiency, re-use and discovery of previously unused resources. A review of location, and energy/material needs within industrial areas can often reveal oppertunities for re-use of what was thought to be a waste product. This can result in significant savings, which provide their own insentive without the need to regulate

  34. March 24, 2010

    A great deal of success in protecting watersheds, water quality, etc. has come from the efforts to educate people about the values of riparian areas and their functions. For over a decade there have been orginizations that have worked towards bringing People, water, soil, and vegetation together
    In the United States we have the National Riparian Service Team (NRST)
    In Alberta Canada there is Cows and Fish

    These are primarily focused on rural streams but the same basic princibles have been applied to the design of urban areas, including the design of the 2010 Olympic Village in Vancover B.C. Aqua-tex is one of the key players in that effort.

    So, the tools are out there.

  35. March 23, 2010

    Ban all toxic lawn treatment chemicals!
    My pond is unusable due to the treated lawns upstream. The fish and frogs are disappearing.
    I am an organic farmer. That is how I make my living. My pond has become nothing but a storm water retention pool for upper-middle class polluters of the earth.
    Millions of gallons of water could be used on my farm if it weren’t for the toxins running off from lawn chemical companies.

  36. March 23, 2010

    One of the main things EPA needs to focus on his Land Application of sewage sludge. Spreading this unknown, potentially toxic material on our farm ground and growing food in it is a very risky health and environmental problem. Scientistssay there are about 80,000 chemicals we use everyday. They can all be in sewage in any combination. The treatment plants can not remove most of them. We must begin to build the new plants that turn sewage sludge into renewable energy before its too late.

  37. March 23, 2010

    To EPA – Treated sewage effluents pollute not only surface waters – but also drinking water.

    HOSPITAL WASTEWATER is particularly dangerous – chemicals, pathogens, MDRB, “maybe even prions” – Humans at risk from surface-derived drinking water – decouple hospitals from public sewers ?

    The inexorable cycle – treated sewage effluent to surface waters — surface water derived drinking water to our taps – chlorination does NOT remove the chemicals, pharma, prions or hardy MDRB pathogens . . . .

    “Humans are particularly exposed by the drinking water, produced from surface water. Microbial agents of special concern are multiresistant microbial strains. The latter are suspected to contribute to the spread of antibiotic resistance.’

    “ABSTRACT – Hospitals discharge considerable amounts of chemicals and microbial agents in their wastewaters. Problem chemicals present in hospital wastewater belong to different groups, such as antibiotics, x-ray contrast agents, disinfectants and pharmaceuticals. Many of these chemical compounds resist normal wastewater treatment. They end in surface waters where they can influence the aquatic ecosystem and interfere with the food chain. Humans are particularly exposed by the drinking water, produced from surface water. Microbial agents of special concern are multiresistant microbial strains. The latter are suspected to contribute to the spread of antibiotic resistance.

    In this paper, we will discuss the different approaches towards hospital wastewater treatment. The Principle of uncoupling hospitals from public sewers warrants in-depth evaluation by technologists and ecotoxicologists as well as public health specialists.’

    “Besides recalcitrant and potent chemicals, hospitals discharge plenty of undesired potentially pathogenic propagules, e.g. antibiotic resistant bacteria, viruses and maybe even prions, etc. ”

    [comment – this article was written in 2006, long before researchers declared that Alzheimer’s Disease (5.3 million victims in US with a new case every 70 seconds) is a prion disease. Numerous researchers have found that human and animal victims of prion diseases shed infectious prions in their urine. ]

    The hospital wastewater article continues:

    “Source separation

    A proposal which has been put forward by Webb et al *(2003) is the source separation of urine of patients which have undergone X-ray imaging. This urine, containing ICMs, can be processed as chemical waste. The same urine source separation could be applied to the urine of pregnant women in the hospital maternity department. This urine can be treated in a small scale WWTP which has been enriched with estrogen degrading organisms.”

    (Estrogens and endocrine disrupters from hospitals and residential sources, flushed to sewage plants, and discharged to surface waters are wreaking havoc by feminizing male fish and harming other aquatic species . . . )

    Helane Shields, Alton, NH

    Infectious human and animal prions in sewage and wastewater:

  38. March 23, 2010

    The downside of state regulation is that when it comes to regulating an industry that is favored, in my case agriculture, the state doesn’t crack down on CAFO’s and other ag related operation like they should. There was a situation in the county I work in where there was a CAFO located 5 feet from a regulated stream and they had been there for years, I finally filed a complaint which forced the State to do an inspection. What they found in their inspection was an operation that was a significant source of pollution for the adjacent stream. The state wasn’t going to do anything unless a formal complaint was filed. So in some cases such as a favored industry it might be better to have direct federal involvment in these areas.

  39. March 23, 2010

    Less talk, more $$$ action: I propose a single solution to help everyone focus better:
    1) Draconian penalties for noncompliance that is either consciously negligent or intentionally concealed, and
    2) Gentle penalties for noncompliance which is self-reported promptly and conscientiously addressed.
    Hit us in the wallet and you have our attention.

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