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AMSA Prepares Comprehensive Commments on EPA Nutrient Guidance
AMSA's Nutrient Workgroup is leading a comprehensive review of the U.S. Environmental Protection Agency's (EPA) nutrient guidance for rivers and streams. The goal of effort is to provide a more scientifically sound, less burdensome approach to controlling nutrients.
AMSA has pursued a thorough response to EPA's nutrients strategy because it has the potential to adversely impact publicly owned treatment works across the country. The Association's Technical Action Fund is supporting AMSA's comprehensive response to this high priority issue.
AMSA has significant concerns regarding both the general approaches identified in the guidance and the potential impacts of criteria that are developed based on these approaches. These concerns arise because no distinction is made between enrichment and impairment of uses, a clearer focus on beneficial uses is needed for public support for the program, and the process places an unfair burden on States and stakeholders.
EPA's Nutrient Approach May Inflate TMDL Lists
AMSA believes that EPA's nutrient guidance could result in needlessly identifying rivers or river segments across the country as “impaired” based simply on nutrient concentration or chlorophyll levels. While nutrient concentrations, chlorophyll, and other water quality measurements could be used as a screening tool to identify river stream segments that may require a more detailed evaluation, AMSA recommends more flexible regulatory approaches so that response actions are limited to those cases where technical demonstrations show that the resident living resources or other defined beneficial uses have been adversely impacted by nutrients.AMSA is seeking an approach that better links nutrient criteria to impacts upon aquatic life or other beneficial uses. AMSA is extremely concerned that POTWs could spend billions of dollars meeting effluent limitations that are driven by non-existent environmental problems.
EPA published a notice of availability for its nutrient criteria technical guidance manual for rivers and streams in the July 27 Federal Register, and AMSA members were notified by FaxAlert. This document provides state water quality managers and others with guidance on how to develop numeric nutrient criteria for rivers and streams.
Under EPA's 1998 Nutrient Strategy, states are required to develop water quality criteria for nitrogen and phosphorus by 2003. EPA is requesting comments on the document by September 25, and AMSA's will be prominent among those submitted. The guidance is available online at www.EPA.gov/OST/standards/nutrient.cfml. A complete copy of AMSA's comments will be posted in the correspondence section of the Member Pipeline at www.amsa-cleanwater.org/private/legreg/outreach.cfm.