regulators force ratepayers' wastewater upgrades, greenhouse
gas emissions increase. Regulating nitrogen releases below 3
mg/L decreases nutrient loads by 1 percent, while increasing
greenhouse gas emissions 70 percent.
19
In the interest of the
environment, when it comes to sewage regulation, we have
come to the point of diminishing returns.
The Idaho Example
The saneness of nonpoint source cures is proven — under EPA
permit — in Idaho. A growing city surrounded by phosphorus-
rich farmland, Boise faced regulatory pressures on its sewage
plant expansion. Avoiding costly conventional upgrades, the
city devised a plan to treat agricultural runoff with simple
alum-based dosing. Their Dixie Drain facility opened this year
at a cost of $17 million, in lieu of spending $55 million for
high-tech wastewater treatment. It only took Boise a decade
with continuous congressional prodding to force EPA to agree
to the innovation.
20
This suggests a better way of doing
business: Call it nutrient farming
or nonpoint source mitigation; it's
really nutrient pollution offsets. As
Boise shows, point sources should be
encouraged to meet permit obligations
with nonpoint source offsets — similar
to Clean Air Act offsets.
Let's get real. Regulating agriculture
is off the table; it's not going to
happen in our lifetime — outside
of a few communal conclaves in California. Barring a game-
changing legal precedent out of Des Moines, the reality is that
farmers will do what we pay them to do. It is economically and
environmentally inefficient to expect otherwise.
A Path Forward
Conventional-thinking engineers argue that wetlands and
bioreactors won't offset pathogenic and other releases. Granted,
but hybrid solutions controlling nutrients and pathogens
collectively (basinwide) will maximize environmental quality at
least cost — better than being held hostage to capital-intensive,
high-tech contraptions tied to massive billable hours for
consulting firms. New thinking and modern monitoring will
remedy the challenges of aggregating and policing nonpoint
source methods, as demonstrated by Dean Lemke's amazing
achievements at the Iowa Department of Agriculture and Land
Stewardship — where the country's most comprehensive plot-
specific inventory of near- or in-field agriculture mitigation
opportunities has been amassed.
It's long past time for a new model. EPA must aggressively
encourage NPDES permit holders with nutrient liabilities
to employ offsets with simple, verifiable technologies. This
must not be confused with "nutrient banking" or "water
quality trading," where environmentalists have hijacked these
convoluted schemes and diluted them with "trading ratios" to
foster perpetual condemnation of agricultural land.
We all eat food, and we're all part of the nutrient cycle. If
sewage fees are a proxy for our collective nutrient pollution,
then (ratepayers') wastewater authorities must be encouraged
to seek least-cost paths to reduce basinwide pollution. EPA and
its guidance should help leaders like Lemke and Stowe work
together. As such an approach improves our water, support for
environmental fundraising and 303(d) litigation evaporates. n
References
1. http://www.esa.org/esa/wp-content/uploads/2013/03/issue3.pdf
2. https://www.epa.gov/sites/production/files/2015-04/documents/
nutrient-economics-report- 2015.pdf
3. http://www.nature.org/ourinitiatives/regions/northamerica/areas/
gulfofmexico/explore/gulf- of-mexico-dead-zone.xml
4. https://www.epa.gov/sites/production/files/2016- 06/documents/
wastewater_progress_report_06142016.pdf
5. http://www.chesapeakebay.net/track/health/bayhealth
6. http://www.cbf.org/about-the-bay/issues/dead-zones/nitrogen-
phosphorus
7. EPA 1991 Guidance for Water Quality Based Decisions (EPA 440/4-
91-001)
8. http://www.circleofblue.org/2015/world/
u-s-clean-water-law-needs-new-act-for-the-
21st- century/ Andreen, Jones, "The Clean
Water Act: A Blueprint for Reform," Center
for Progressive Reform, 2008.
9. ftp://ft.dphe.state.co.us/wqc/
wqcc/31_85NutrientsRMH_2012/
RebuttalStatements/Metro.pdf
10. Testimony of Barbara Biggs, before the
Subcommittee on Water Resources and
Environment, House Transportation and
Infrastructure Committee, U.S. House of
Representatives, June 24, 2011.
11. http://www.iowapolicyproject.
org/2011Research/110622-wetlands.html
12. Supreme Court of Iowa, Board of Water Works Trustees of the City of
Des Moines, Iowa, vs Sac County, et al., No. 16-0076, January 27, 2017.
13. "Iowa Nutrient Reduction Strategy", Iowa Department of Agriculture
and Land Stewardship, Iowa Department of Natural Resources, May
2013. Released November 2012.
14. Andrews, Barnard, et al, "An Innovative Approach to Nitrate
Removal: Making a Dent in the Gulf of Mexico Hypoxia," WEFTEC
2006.
15. http://www.rrstar.com/article/20150418/NEWS/150419465
16. Harper, Coleman, et al, "Analysis of Nutrient Removal Costs in the
Chesapeake Bay Program and Implications for the Mississippi-Atchafalaya
River Basin, 2008 WEFTEC Conference.
17. http://www.prairiefirenewspaper.com/2008/08/nutrient-farming
18. NACWA, "Controlling Nutrient Loadings to U.S. Waterways: An
Urban Perspective," 2011.
19. Neethling, Reardon, HDR Engineering, "When do the costs of
wastewater treatment outweigh the benefits of nutrient removal?" WERF,
2011.
20. U.S. Environmental Protection Agency, Proposes to Reissue a
National Pollutant Discharge Elimination System Permit, West Boise
Wastewater Treatment Facility, City of Boise, NPDES Permit No
ID-0023981, October 2011.
wateronline.com
n
Water Innovations
Mark Gibson is the principal at Kyklos Engineering, LLC, a public
affairs and business development consulting firm. He has three
decades of experience in energy and environmental policy and
degrees in engineering and economics.
About The Author
REGULATIONS
10
New thinking and modern
monitoring will remedy the
challenges of aggregating
and policing nonpoint
source methods.