Water Online

May 2017

Water Innovations gives Water and Wastewater Engineers and end-users a venue to find project solutions and source valuable product information. We aim to educate the engineering and operations community on important issues and trends.

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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.

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