Many state water quality standards were established shortly after the Clean Water Act was adopted in 1972 when a key goal was to eliminate pollutant discharge to navigable waters by 1985. Unfortunately, this admirable goal sometimes has resulted in pollutant-reduction requirements that are based on unattainable water quality standards that reflect the environmental euphoria of the 1970s and 1980s.
It is wise to consider whether we should continue to develop water quality management plans focused on achieving those goals or whether it would be better to develop realistic goals and set attainable water quality standards.
From a pragmatic perspective, working toward unattainable water quality standards makes it difficult to achieve widespread buy-in on pollutant load controls.
I see this reaction now in North Carolina, where unattainable standards are leading to a backlash against pollutant reduction, due primarily to the extremely high costs of compliance. Unfortunately, long lag times between implementing nonpoint source controls and observable water quality improvements lead to skepticism that the requirements will have any effect.
For example, Falls Reservoir in North Carolina has a mandate to reduce phosphorus loading by 77 percent to reach its chlorophyll water quality criterion. Given the preponderance of nonpoint sources of phosphorus in the Falls Reservoir watershed, a 77 percent reduction is not feasible. Even if it were, the cost of attainment almost certainly would far exceed the benefits derived for designated use. Given that situation, Falls Reservoir needs a Use Attainability Analysis to determine whether a designated use, such as recreational fishing, is technologically and economically feasible or a new site-specific nutrient criteria.
Realistic and achievable water quality standards, with designated use improvements causally linked to attaining water quality criteria regarding chlorophyll, are needed to gain widespread support for pollutant controls. In Falls Reservoir, the backlash against the high cost of phosphorus load reductions has resulted in a state-sponsored plan for in-lake artificial mixing using SolarBees. This is a waste of money.
Whole-lake mixing is not feasible due to the large size of Falls Reservoir, and in-lake mixing will have little effect on nutrient concentrations. Though such mixing is not scientifically defensible, I understand that local and state elected officials may feel desperate enough to embrace even ineffective “solutions” in the hope of reducing pollutant control costs for their constituents.
It is unfortunate that the laudatory goals of the Clean Water Act are not everywhere attainable. The most effective way to better protect designated uses would be to adopt technologically and economically feasible water quality standards.
I wish we could do better and eliminate pollutant discharges to navigable waters, but that is not going to happen. Recognizing the need to set realistic water quality goals is the best way to achieve and maintain meaningful water quality improvements.
Dr. Kenneth H. Reckhow is professor emeritus in the Nicholas School of the Environment at Duke University.