It’s The Watershed

NACWA advocates control of nonpoint pollution sources as a key to reducing nutrient loadings to the nation’s waters.
It’s The Watershed
Chris Hornback

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Editor's Note: The National Association of Clean Water Agencies recently announced a partnership with the National Milk Producers Federation to make watershed-level water quality improvements. To read more about this important agreement, see "National Association of Clean Water Agencies Partners with National Milk Producers Federation."

 As clean-water plants face tightening permit limits for nitrogen and phosphorus, communities and their utilities increasingly look upstream for solutions.

In most watersheds, more nutrients enter the waterways through nonpoint sources than from treatment plant outfalls, and it makes sense to look for ways to reduce those loadings as a big part of the answer to nutrient pollution. That’s the position of the National Association of Clean Water Agencies (NACWA), a nationally recognized advocate for sound environmental policy and a technical resource on issues related to water quality and ecosystem protection.

NACWA has advocated for clean-water agencies since 1970 and the passage of the first federal Clean Water Act, and since the late 1990s it has been on the forefront of policy development related to nutrient issues. Chris Hornback, NACWA’s senior director of regulatory affairs, talked about current issues with nitrogen and phosphorus regulation in an interview with Treatment Plant Operator.

TPO: What is the history of NACWA’s involvement with nutrient issues?

Hornback: Nutrients, specifically nitrogen and phosphorus, have been a top priority for us for the entire 13 years I have been here and even before that. In the late 1990s, the U.S. EPA began to develop criteria and policy statements on the need to address nutrient discharges. Starting about then and into the early 2000s when the EPA began developing national recommended eco-regional criteria for nutrients, we were actively engaged, since our members were the primary, easily controllable sources of nutrients.

TPO: Why is it important to look at entire watersheds when striving to reduce nutrient contributions to the rivers, lakes and oceans?

Hornback: We’ve seen over the last decade that failure to look at watersheds leads to a lopsided approach to dealing with nutrients. We’ve been talking about watershed approaches since the early 1990s, when we first tried to work with Congress to develop a better approach to water quality. That has grown into a nutrients issue, and nutrients are probably the best case study for why we need a watershed approach. You can have multiple sources in a watershed that contribute to the problem, yet the inclination from regulatory authorities has been to go after the entities that hold discharge permits.

We see watersheds where point sources have been taken down to the limits of technology, yet they are less than a fifth of the nutrient contributions. If you look at the Chesapeake Bay, the clean-water plant in Washington, D.C., is installing another round of nutrient removal technology that will take its effluent total nitrogen from 5 mg/L to 4 mg/L. In terms of the volume of their flow, that is a significant reduction in the mass of nutrients, but it’s going to cost them $900 million.

As the permit limits get lower, the cost of removal gets higher and higher, and from our perspective it’s time to look at broader watershed approaches. If we’re looking at the Chesapeake Bay, we should spend that $900 million where it would have the biggest bang for the buck, and that’s not on point-source control at one treatment plant on the Potomac River.

TPO: Has there been progress in nutrient removal technology for treatment plants?

Hornback: In our industry, we are engineers. We very much like to engineer solutions, and so we’ve been able to engineer technology to remove nutrients to lower and lower levels. In some cases we’re finding cutting-edge technologies that will allow us to do that while using less energy and less chemicals. But we still come back to the question: Is that really the best way to go about this?

TPO: In watersheds, what is typical in terms of percentage of nutrient contribution, if there is such a thing as typical?

Hornback: It really varies from watershed to watershed. In the Chesapeake Bay, for example, point sources are less than 20 percent of the contribution. A good share is from urban runoff, but the largest contribution is from agricultural runoff, and 20 percent of the nitrogen is from air deposition — a very tough nut to crack. In the Mississippi River basin and the Gulf of Mexico, I have seen 80 to 95 percent of the nutrients going into the Gulf attributed to nonpoint sources, notably agricultural runoff. Point sources are not insignificant in that major wastewater treatment plants discharge into that watershed, but even if you took them all to zero, it wouldn’t address the problem in the Gulf.

TPO: Are there watersheds where the shares of nutrient contribution are reversed — where point sources are the largest contributors?

Hornback: There are watersheds where we see larger point-source contributions. Long Island Sound is one of those. Certain rivers, such as the South Platte in Colorado, are dominated by wastewater effluent. In cases like those, you’re going to have much more significant point-source contribution. So it’s not a one-size-fits-all picture.

TPO: Can you cite examples where broadly focused watershed approaches have been effective in reducing nutrients?

Hornback: Those are difficult to find. On Long Island Sound, the treatment plants in Connecticut have formed a nutrient credit trading program. They look at their aggregate discharges into the sound and they manage the loadings among the utilities. Plants that install treatment and exceed their removal requirements may generate credits that other plants in the watershed can purchase to offset their requirements. These are point-source to point-source arrangements.

There is a similar trading program on the Neuse River in North Carolina, but there unfortunately, while the point sources have made dramatic reductions in their nutrient releases, the watershed is not any better because the nonpoint sources have actually increased their discharges.

A utility that has used a watershed approach, though not specifically for nutrients, is Clean Water Services in Oregon. They have to comply with temperature standards on the Tualatin River to meet cold-water requirements for salmon and other fish. They either needed to chill their effluent, which would have been expensive, or go upstream and work with landowners to plant trees to increase tree cover and reduce the temperature naturally — which is what they have done.

TPO: What is being done to engage the agricultural community in helping to reduce runoff and nutrient contributions?

Hornback: Maryland is a rare example of a state with a nutrient management program that does require some programs and practices from farmers. The federal government has significant investments in conservation programs through the Farm Bill that encourage farmers to put conservation practices in place, but those are spread out across the country. We’re just getting into newer versions of those programs, where they’re trying to target dollars to the watersheds that need them most. But those efforts are not coordinated, and they are certainly not mandated through the Clean Water Act.

TPO: If the focus for nutrient reduction is to shift upstream, who will actually do the work of implementing practices to reduce nonpoint source contributions?

Hornback: That’s a challenge because concerns have been raised about utilities taking ratepayer money and going upstream to do work. We need to ask whether we should spend money on improvements upstream that will save us money in the long run, or continue with concrete and steel solutions. The new Farm Bill includes a Regional Conservation Partnership Program (RCPP) designed to encourage farmers to partner with a wastewater utility to target watershed-specific needs. The money goes to the farmers, but the partnership creates links to watershed entities to make sure watershed goals are met.

TPO: What is the relative importance of nitrogen and phosphorus in nutrient management?

Hornback: In areas like the Chesapeake Bay and the Mississippi River, the focus is entirely on nitrogen because that nutrient is having the most impact on the estuarine systems. The dead zone in the Gulf and the hypoxia in the bay are caused by nitrogen.

In Wisconsin and Great Lakes states with major freshwater systems, phosphorus is the limiting nutrient and has the biggest impact. The EPA is very much focused on both. They believe that ultimately every state should have numeric water-quality criteria for both nitrogen and phosphorus. In their view, both are equally destructive and need to be addressed on an equal level.  

TPO: What can clean-water agencies do on their own to effect responsible progress on nutrient issues?

Hornback: One challenge related to the nutrient issue is a lack of good monitoring data. Utilities are often hesitant to monitor for things they’re not regulated for because that could actually lead to regulation. Yet without good monitoring, it’s difficult for the point-source community to point to data and say, ‘Look, we’re only X percent of the discharge — our monitoring shows that there are other bigger sources of nitrogen and phosphorus that we really should be going after.’ The lack of data is hurting us in the long run.

The states don’t have the resources to do a lot of water-quality monitoring. Understanding where your discharges are in quantities of nitrogen and phosphorus can be a powerful tool as you talk with regulators. Some utilities have made a conscious decision that they’re going to monitor for these parameters and arm themselves with good data, both in terms of their own discharge and the water quality in the watershed.

TPO: What advice do you have for clean-water agencies as it relates to engaging with the regulatory community?

Hornback: One thing we recommend to our members is to stay in contact with their state regulators and make sure they understand where they are in the regulatory process. For example, when Wisconsin started to develop its phosphorus rules, the utilities there were very engaged and were able to sit down with the regulators and talk them through some of the challenges. It’s good to be involved and engaged early in the process and not wait until the end when the regulators come out with a proposed rule and say, ‘Here it is — what do you think?’

Getting engaged can be hard for small and mid-size utilities that don’t have staff dedicated to regulatory issues. That’s where NACWA, the Water Environment Federation, state and regional Water Environment Associations and state utility organizations can keep tabs on things.

TPO: Do you see progress in nutrient reduction from the nonpoint-source side?

Hornback: We have yet to see true meaningful reductions there. Around the Chesapeake Bay, for example, nonpoint source interests are aggressively fighting any obligations under total maximum daily loads and other Clean Water Act provisions. We continue to see aggressive pushback from national farm groups.

The RCPP is promising. We also see some utilities starting to ask: If we can’t get to nonpoint sources through regulatory means, what is another meaningful way? Chicago is really starting to think outside the box and explore how to partner and engage directly with agricultural interests and work with them to solve problems.

We see communities starting to explore nontraditional partnerships — nothing that’s ready for prime time, but people are starting to talk about how to engage farm interests in ways that make them more comfortable coming to the table. There is definitely interest in finding ways to talk to them in their language about working collaboratively toward solutions. We’re going to see more of that in the next couple of years.   


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