Water Quality
EPA Should Improve Guidance and Support to Help States Develop Standards That Better Target Cleanup Efforts Gao ID: GAO-03-881T June 19, 2003Water quality standards comprise designated uses and water quality criteria. These standards are critical in making accurate, scientifically based determinations about which of the nation's waters are most in need of cleanup. GAO examined the extent to which (1) states are changing designated uses when necessary, (2) EPA is assisting states toward that end, (3) EPA is updating the "criteria documents" states use to develop the pollutant limits needed to measure whether designated uses are being attained, and (4) EPA is assisting states in establishing criteria that can be compared with reasonably obtainable monitoring data.
The extent to which states are changing designated uses varies considerably. Individual states made anywhere from no use changes to over 1,000 use changes during the 5-year period, from 1997 through 2001. Regardless of the number of use changes states made, nearly all states report that some water bodies within their states currently need changes to their designated uses. To do so, many states said they need additional EPA assistance to clarify the circumstances in which use changes are acceptable to EPA and the evidence needed to support those changes. While EPA has developed and published criteria for a wide range of pollutants, the agency has not updated its criteria documents to include sedimentation and other key pollutants that are causing approximately 50 percent of water quality impairments nationwide. In addition to needing new criteria documents, states need assistance from EPA in establishing criteria so that they can be compared with reasonably obtainable monitoring data. Changing either designated uses or criteria is considered a standards modification. Twenty-two states reported that an improvement in the process for changing designated uses would result in different water bodies being slated for cleanup; 22 states also reported that an improvement in the process for modifying criteria would have that effect. Collectively, 30 states would have different water bodies slated for cleanup with an improvement in the process of modifying standards.
GAO-03-881T, Water Quality: EPA Should Improve Guidance and Support to Help States Develop Standards That Better Target Cleanup Efforts
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Testimony:
Before the Subcommittee on Water Resources and Environment, Committee
on Transportation and Infrastructure, House of Representatives:
United States General Accounting Office:
GAO:
For Release on Delivery Expected at 10:00 a.m. EDT:
Thursday, June 19, 2003:
Water Quality:
EPA Should Improve Guidance and Support to Help States Develop
Standards That Better Target Cleanup Efforts:
Statement of John B. Stephenson, Director Natural Resources and
Environment:
GAO-03-881T:
GAO Highlights:
Highlights of GAO-03-881T, a report to the Subcommittee on Water
Resources and Environment, Committee on Transportation and
Infrastructure, House of Representatives
Why GAO Did This Study:
Water quality standards comprise designated uses and water quality
criteria. These standards are critical in making accurate,
scientifically based determinations about which of the nation‘s waters
are most in need of cleanup. GAO examined the extent to which (1)
states are changing designated uses when necessary, (2) EPA is
assisting states toward that end, (3) EPA is updating the ’criteria
documents“ states use to develop the pollutant limits needed to
measure whether designated uses are being attained, and (4) EPA is
assisting states in establishing criteria that can be compared with
reasonably obtainable monitoring data.
What GAO Found:
The extent to which states are changing designated uses varies
considerably. Individual states made anywhere from no use changes to
over 1,000 use changes during the 5-year period, from 1997 through
2001. Regardless of the number of use changes states made, nearly all
states report that some water bodies within their states currently
need changes to their designated uses. To do so, many states said
they need additional EPA assistance to clarify the circumstances in
which use changes are acceptable to EPA and the evidence needed to
support those changes.
While EPA has developed and published criteria for a wide range of
pollutants, the agency has not updated its criteria documents to
include sedimentation and other key pollutants that are causing
approximately 50 percent of water quality impairments nationwide. In
addition to needing new criteria documents, states need assistance
from EPA in establishing criteria so that they can be compared with
reasonably obtainable monitoring data.
Changing either designated uses or criteria is considered a standards
modification. Twenty-two states reported that an improvement in the
process for changing designated uses would result in different water
bodies being slated for cleanup; 22 states also reported that an
improvement in the process for modifying criteria would have that
effect. Collectively, 30 states would have different water bodies
slated for cleanup with an improvement in the process of modifying
standards.
What GAO Recommends:
GAO recommended in its January 2003 report that the Administrator, EPA
(1) provide additional guidance regarding use changes, (2) follow
through on plans to assess the feasibility of establishing a
clearinghouse of approved use changes, (3) set a time frame
specifically for the development of sediment criteria, (4) develop
alternative, scientifically defensible monitoring strategies that
states can use to determine if water bodies are meeting their water
quality criteria, and (5) develop guidance and a training strategy to
help EPA regional staff in determining the scientific defensibility of
proposed criteria modifications. EPA agreed with GAO‘s
recommendations and plans to take steps to address them.
www.gao.gov/cgi-bin/getrpt?GAO-03-881T.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact John B. Stephenson at
(202) 512-3841 or stephensonj@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
Thank you for the opportunity to discuss our work assessing the
Environmental Protection Agency's (EPA) and states' actions under the
Clean Water Act to improve water quality standards. Water quality
standards are critical in making accurate, scientifically based
determinations about which waters are most in need of attention.
Without accurate standards, our nation runs the risk of wasting
valuable resources by "overprotecting" some waters or facing
unacceptable environmental consequences by "underprotecting" others.
Water quality standards comprise two key components--designated uses
and water quality criteria. States are responsible under the Clean
Water Act both for determining uses and for setting criteria. Both
actions require EPA approval.
Designated uses identify the purposes for which a given body of water
is intended to serve, such as drinking water, contact recreation (e.g.,
swimming), and aquatic life support (e.g., fishing). Water quality
criteria are used to determine whether a water body is achieving its
designated uses by specifying pollutant limits, such as the maximum
allowable concentration of a pollutant, or an important physical or
biological characteristic that must be met (for example, an allowable
temperature range). To develop criteria, states rely heavily on EPA-
developed "criteria documents." These documents contain the technical
data that help states adopt pollutant levels that, if not met, may
preclude a water body from supporting its designated uses. States may
adopt these criteria as recommended by EPA, adapt them to meet state
needs, or develop their own criteria using other scientifically
defensible methods.
The Clean Water Act also requires that states periodically review their
standards and revise them as needed. Before any revisions can take
effect, however, a state must submit them to its EPA regional office
for approval. Periodic review and revision of water quality standards
is important because the standards serve as the foundation of several
water quality programs, such as the Total Maximum Daily Load (TMDL)
program. Under this key program, waters that do not achieve water
quality standards are listed as impaired and then targeted for cleanup.
According to EPA, over 20,000 bodies of water throughout the United
States are impaired by one or more pollutants.
In recent years, questions have been raised as to whether current water
quality standards are accurate and, therefore, whether the right waters
are being targeted for cleanup. My testimony will discuss our January
2003 report on this subject, which was prepared at this Subcommittee's
request.[Footnote 1] As requested, we examined the extent to which (1)
states are changing designated uses when necessary, (2) EPA is
assisting states toward that end, (3) EPA is updating the criteria
documents states use to develop the pollutant limits needed to measure
whether designated uses are being attained, and (4) EPA is assisting
states in establishing criteria that can be compared with reasonably
obtainable monitoring data.
To respond to the request, we conducted a Web-based survey of the 50
states and the District of Columbia. We also interviewed officials from
the 10 EPA regional offices and conducted site visits to Kansas,
Montana, and Ohio. We also met with, and obtained information from,
officials from EPA's headquarters and the Association of State and
Interstate Water Pollution Control Administrators. Finally, we
interviewed representatives of various interest groups, such as
Earthjustice and the American Farm Bureau Federation.
In summary, Mr. Chairman, we found the following:
* The extent to which states are changing designated uses varies
considerably. Individual states made anywhere from no changes to over
1,000 changes during the 5-year period, from 1997 through 2001.
Regardless of the number of use changes states have made to date,
however, nearly all states reported that they have water bodies within
their states that currently need changes to their designated uses.
According to the states, they have not made needed designated use
changes because of a number of barriers, including inadequate
monitoring data and resistance from interest groups and affected
parties. Importantly, another key reason has been uncertainty over the
circumstances in which use changes are acceptable to EPA and the
evidence needed to support those changes.
* Many states said they need additional assistance from EPA to make
accurate and defensible decisions on what some believe will be a much
larger number of designated use changes in coming years. Specifically,
they cited a need for additional EPA guidance to clarify both the
circumstances under which use changes are acceptable and the type of
evidence needed to support those changes. EPA headquarters officials
acknowledge this need and have formed a national working group to
develop additional guidance on designated use changes. Such guidance
would also (1) help clarify to EPA regional officials what state-
proposed changes are acceptable and (2) promote more consistent review
and approval policies across EPA's 10 regional offices.
* As required, EPA has developed and published criteria for a wide
range of pollutants. However, EPA has not developed criteria for
sedimentation (e.g., sand and silt accumulation) and is currently
developing the complex criteria needed for nutrients (e.g., phosphorus
from fertilizers and nitrogen from animal waste). According to EPA
data, sedimentation and nutrients are key pollutants responsible for a
relatively large share of the nation's impaired waters. Hence, it is
not surprising that states responding to our survey rank these two
pollutants as their highest priorities for criteria development.
* Even when EPA has developed criteria documents, some states have
reported difficulty in using the documents to establish criteria in
such a way that the criteria can be easily compared with reasonably
obtainable monitoring data. As a related matter, states also expressed
difficulty in modifying the criteria they already have in place, when
necessary, to reflect new data or changing ecological conditions. While
most states cited resource constraints as a barrier that affects their
ability to make criteria modifications, more than half of the states
also cited EPA's approval process--noting, for example, insufficient
assistance from their respective EPA regional offices in helping them
understand the data necessary to justify a criteria modification.
The difficulty states have had in developing accurate water quality
standards has important implications for their efforts to correctly
identify which of their waters are impaired. If they cannot use their
standards to accurately target their impaired waters, they risk
focusing their limited resources on cleaning up the wrong water bodies
and/or exposing their citizens to health and environmental risks.
Thirty states reported in response to our survey that if EPA improved
the process of modifying standards through changes to designated uses
and/or criteria, they would identify different waters for TMDL
development. Significantly, this total does not reflect the effects on
lists of impaired waters of new criteria for sedimentation and other
pollutants being developed by EPA and the states. These criteria are
also likely to affect which waters states list as impaired.
Background:
Designated uses are the purposes that a state's waters are intended to
serve. Some waters, for example, serve as a drinking water source,
while others are designated to serve as a source of recreation
(swimming or boating) and/or to support aquatic life. The state must
also develop water quality criteria, which specify pollutant limits
that determine whether a water body's designated use is achieved. These
water quality criteria can be expressed, for example, as the maximum
allowable concentration of a given pollutant such as iron, or as an
important physical or biological characteristic that must be met, such
as an allowable temperature range.
To develop water quality criteria, states rely heavily on EPA-developed
"criteria documents." These documents contain the technical data that
allow states to develop the necessary pollutant limits. EPA is
responsible for developing and revising criteria documents in a manner
that reflects the latest scientific knowledge. States may adopt these
criteria as recommended by EPA, adapt them to meet state needs, or
develop criteria using other scientifically defensible methods.
States are also required to periodically review both their waters'
designated uses and associated criteria, and make changes as
appropriate. Before those changes can take effect, the state must
submit them to EPA and obtain approval for them. EPA is required to
review and approve or disapprove standards changes proposed by a state
within 60 to 90 days.
Figure 1 illustrates how states use water quality standards to make key
decisions on which waters should be targeted for cleanup. States
generally determine if a water body's designated use is achieved by
comparing monitoring data with applicable state water quality criteria.
If the water body fails to meet the applicable standards, the state is
required to list that water as "impaired"; calculate a pollution budget
under EPA's Total Maximum Daily Load program that specifies how
compliance with the standard can be achieved; and then eventually
implement a cleanup plan. Thus, as noted in 2001 by the National
Academy of Sciences' National Research Council,[Footnote 2] water
quality standards are the foundation on which the entire TMDL program
rests: if the standards are flawed, all subsequent steps in the TMDL
process will be affected.
Figure 1: Water Quality Standards as the Basis for Cleanup Decisions:
[See PDF for image]
[End of figure]
States' Practices in Changing Designated Uses Vary Widely:
We asked the states to report the total number of designated use
changes they adopted from 1997 through 2001. While some states made no
use changes, others made over 1,000 changes. At the same time, nearly
all states told us that designated use changes are needed. Twenty-
eight states reported that between 1 to 20 percent of their water
bodies need use changes; 11 states reported that between 21 and
50 percent of their water bodies need use changes; and 5 states
reported that over 50 percent of their water bodies need use changes.
These percentages suggest that future use changes may dwarf the few
thousand made between 1997 and 2001. For example, Missouri's response
noted that while the state did not make any use changes from 1997
through 2001, approximately 25 percent of the state's water bodies need
changes to their recreational designated uses and more changes might be
needed for other use categories as well. Similarly, Oregon's response
noted that while the state made no use changes from 1997 through 2001,
the state needs designated use changes in over 90 percent of its
basins.
Many states explained their current need to make designated use changes
by noting, among other things, that many of the original use decisions
they made during the 1970s were not based on accurate data. For
example, Utah's response noted that because of concerns that grant
funds would be withheld if designated uses were not assigned quickly,
state water quality and wildlife officials set designated uses over a
4-to 5-day period using "best professional judgment." As states have
collected more data in ensuing years, the new data have provided
compelling evidence that their uses are either under-or over-
protective.
In addition to changing designated uses for individual waters to
reflect the new data, some states are seeking to develop more
subcategories of designated uses to make them more precise and
reflective of their waters' actual uses. For example, a state may
wish to create designated use subcategories that distinguish between
cold and warm water fisheries, as opposed to a single, more general
fishery use. Developing these subcategories of uses has the potential
to result in more protective uses in some cases, and less protective
uses in others.
EPA Assistance and Guidance Needed to Help States Make Defensible
Designated Use Changes:
According to responses to our survey, a key reason state officials have
not made more of the needed designated use changes is the uncertainty
many of them face over the circumstances in which use changes are
acceptable to EPA and the evidence needed to support these changes. EPA
regulations specify that in order to remove a designated use, states
must provide a reason as to why a use change is needed and demonstrate
to EPA that the current designated use is unattainable. To do this,
states are required to conduct a use attainability analysis (UAA).
A UAA is a structured, scientific assessment of the factors affecting
the attainment of the use, which may include physical, chemical,
biological, and economic factors. The results of a state's analysis
must be included in its submittal for a use change to EPA. States that
want to increase the stringency of a designated use are not required to
conduct a UAA.
UAAs vary considerably in their scope and complexity and in the time
and cost required to complete them. They can range from 15-minute
evaluations that are recorded on a single worksheet to more complex
analyses that might require years to complete. A Virginia water quality
official explained, for example, that some of the state's UAAs are
simple exercises using available data, while others require more
detailed analysis involving site visits, monitoring, and laboratory
work. In their responses to our survey, states reported that the UAAs
they conducted in the past 5 years have cost them anywhere from $100
to $300,000.
In 1994, EPA published guidance regarding use changes that specifies
the reasons states may remove a designated use. Nonetheless, our survey
shows that many states are still uncertain about when to conduct UAAs,
or about the type or amount of data they need to provide to EPA to
justify their proposed use changes. Forty-three percent of states
reported that they need additional clarifying UAA guidance. Among them,
Oregon's response explained that water quality officials need guidance
on whether a UAA is required to add subcategories of use for particular
fish species. Virginia's response indicated that the state needs
guidance on what reasons can justify recreational use changes, noting
further that state water quality officials would like to see examples
of UAAs conducted in other states. Louisiana's response similarly
called for specific guidance on what type of and how much data are
required for UAAs in order for EPA to approve a designated use change
with less protective criteria.
EPA headquarters and regional officials acknowledge that states are
uncertain about how to change their designated uses and believe better
guidance would serve to alleviate some of the confusion. Of particular
note, officials from 9 of EPA's 10 regional offices told us that states
need better guidance on when designated use changes are appropriate and
the data needed to justify a use change. Chicago regional officials,
for example, explained that the states in their region need
clarification on when recreational use changes are appropriate and the
data needed to support recreational use changes.
In this connection, an official from the San Francisco regional office
suggested that headquarters develop a national clearinghouse of
approved use changes to provide examples for states and regions of what
is considered sufficient justification for a use change. A 2002 EPA
draft strategy also recognized that this type of clearinghouse would be
useful to the states. The strategy calls on EPA's Office of Science and
Technology to conduct a feasibility study to identify ways to provide a
cost-effective clearinghouse. According to EPA, the agency plans to
conduct the feasibility study in 2004.
EPA headquarters officials have also formed a national working group to
address the need for guidance. According to the officials, the group
plans to develop outreach and support materials addressing nine areas
of concern for recreational uses that states have identified as
problematic. In addition, the group plans to develop a Web page that
includes examples of approved recreational use changes by the end of
2004.
The national work groups' efforts may also help address another concern
cited by many states--a lack of consistency among EPA's regional
offices on how they evaluate proposals by their states to change
designated uses. Some states' water quality officials noted in
particular that the data needed to justify a use change varies among
EPA regions. For example, Rhode Island's response asserted that the
state's EPA regional office (Boston) requires a much greater burden of
proof than EPA guidance suggests or than other regional offices
require. The response said that EPA guidance on UAAs should be more
uniformly applied by all EPA regional offices. Several EPA regional
officials acknowledged the inconsistency and cited an absence of
national guidance as the primary cause.
EPA headquarters officials concurred that regional offices often
require different types and amounts of data to justify a use change and
noted that inconsistency among EPA regional offices' approaches has
been a long-standing concern. The officials explained that EPA is
trying to reduce inconsistencies while maintaining the flexibility
needed to meet region-specific conditions by holding regular work group
meetings and conference calls between the regional offices and
headquarters.
EPA Has Not Developed and Updated Key Criteria Documents:
While EPA has developed and published criteria documents for a wide
range of pollutants, approximately 50 percent of water quality
impairments nationwide concern pollutants for which there are no
national numeric water quality criteria. Because water quality criteria
are the measures by which states determine if designated uses are being
attained, they play a role as important as designated uses in states'
decisions regarding the identification and cleanup of impaired waters.
If nationally recommended criteria do not exist for key pollutants, or
if states have difficulty using or modifying existing criteria, states
may not be able to accurately identify water bodies that are not
attaining designated uses.
Sedimentation is a key pollutant for which numeric water quality
criteria need to be developed. In addition, nutrient criteria are
currently being developed, and pathogen criteria need to be revised.
Together, according to our analysis of EPA data, sediments, nutrients,
and pathogens are responsible for about 40 percent of impairments
nationwide. (See fig. 2.) Not surprisingly, many states responding to
our survey indicated that these pollutants are among those for which
numeric criteria are most needed.[Footnote 3]
Figure 2: Percent of Impairments Nationwide Caused by Various
Pollutants:
[See PDF for image]
[End of figure]
Recognizing the growing importance of pathogens in accounting for the
nation's impaired waters, EPA developed numeric criteria for pathogens
in 1986--although states are having difficulty using these criteria and
are awaiting additional EPA guidance. EPA is also currently working
with states to develop nutrient criteria and has entered into a
research phase for sedimentation. EPA explained that the delay in
developing and publishing key criteria has been due to various factors,
such as the complexity of the criteria and the need for careful
scientific analysis, and an essentially flat budget accompanied by a
sharply increased workload. EPA also explained that for several
decades, the agency and the states focused more on point source
discharges of pollution, which can be regulated easily through permits,
than on nonpoint sources, which are more difficult to
regulate.[Footnote 4]
States Need EPA Assistance to Establish Criteria That Can Be Compared
to Reasonably Obtainable Monitoring Data:
Even when EPA has developed criteria recommendations, states reported
that the criteria cannot always be used because water quality officials
sometimes cannot perform the kind of monitoring that the criteria
documents specify, particularly in terms of frequency and duration. Our
survey asked states about the extent to which they have been able to
establish criteria that can be compared with reasonably obtainable
monitoring data. About one-third reported that they were able to do so
to a "minor" extent or less, about one-third to a "moderate" extent,
and about one-third to a "great" extent. Mississippi's response noted,
for example, that the state has adopted criteria specifying that
samples must be collected on 4 consecutive days. The state noted,
however, that its monitoring and assessment resources are simply
insufficient to monitor at that frequency. Mississippi is not alone: a
2001 report by the National Research Council found that there is often
a "fundamental discrepancy between the criteria used to determine
whether a water body is achieving its designated use and the frequency
with which water quality data are collected." To address this
discrepancy, regional EPA officials have suggested that EPA work with
the states to develop alternative methods for determining if water
bodies are meeting their criteria, such as a random sampling approach
to identify and set priorities for impaired waters.
If a state believes that it can improve its criteria, it has the option
of modifying them--with EPA's approval. In fact, states are required to
review and modify their criteria periodically. A state might modify a
criterion, for example, if new information becomes available that
better reflects local variations in pollutant chemistry and
corresponding biological effects.
In response to our survey, 43 states reported that it is "somewhat" to
"very" difficult to modify criteria. Not surprisingly, a vast majority
of states reported that a lack of resources (including data, funding,
and expertise) complicates this task. Nevada's response, for example,
explained that, like many states, it typically relies on EPA's
recommended criteria because of limited experience in developing
criteria as well as limited resources; in many instances, developing
site-specific criteria would better reflect unique conditions, allowing
for better protection of designated uses. Significantly, however, more
than half of the states reported that EPA's approval process serves as
a barrier when they try to modify their criteria. In this connection,
respondents also noted that EPA's regional offices are inconsistent in
the type and amount of data they deem sufficient to justify a criteria
change. Some regional officials told us that this inconsistency is
explained, in part, by staff turnover in the regional offices.
Likewise, a 2000 EPA report found that less tenured staff in some
regional offices often lack the technical experience and skill to work
with the states in determining the "scientific feasibility" of
state-proposed criteria modifications. Our report concluded that
additional headquarters guidance and training of its regional water
quality standards staff would help facilitate meritorious criteria
modifications while protecting against modifications that would result
in environmental harm.
Improvements to Designated Uses and Criteria Could Have a Large and
Cumulative Impact on Impaired Waters Lists:
Because designated uses and criteria constitute states' water quality
standards, a change in either is considered a standards modification.
We first asked the states whether an improvement in the process of
changing designated uses would result in different water bodies being
slated for cleanup within their states, and 22 states reported
affirmatively. We then asked the states whether an improvement in the
process of modifying criteria would result in different water bodies
being slated for cleanup within their states, and 22 states reported
affirmatively. As figure 3 shows, when we superimposed the states'
responses to obtain the cumulative effect of improving either
designated uses or the process of criteria modification, a total of 30
states indicated that an improvement in the process of modifying
standards (whether a change in their designated uses, their criteria,
or both) would result in different water bodies being slated for
cleanup.
Figure 3: States Reporting That Different Water Bodies Would Be Slated
for Cleanup if Improvements Were Made to the Process of Changing
Standards:
[See PDF for image]
[End of figure]
Importantly, the 30-state total does not reflect the impacts that would
result from EPA's publication (and states' subsequent adoption) of new
criteria for sedimentation and other pollutants, nor does it reflect
states' ongoing adoption of nutrient criteria. As these criteria are
issued in coming years, states will adopt numeric criteria for these
key pollutants, which, in turn, will likely affect which waters the
states target for cleanup.
To help ensure that both designated uses and water quality criteria
serve as a valid basis for decisions on which of the nation's waters
should be targeted for cleanup, we recommended that the Administrator
of EPA take several actions to strengthen the water quality standards
program. To improve designated uses, we recommended that EPA (1)
develop additional guidance on designated use changes to better clarify
for the states and regional offices when a use change is appropriate,
what data are needed to justify the change, and how to establish
subcategories of uses and (2) follow through on its plans to assess the
feasibility of establishing a clearinghouse of approved designated use
changes by 2004. To improve water quality criteria, we recommended that
EPA (1) set a time frame for developing and publishing nationally
recommended sedimentation criteria, (2) develop alternative,
scientifically defensible monitoring strategies that states can use to
determine if water bodies are meeting their water quality criteria, and
(3) develop guidance and a training strategy that will help EPA
regional staff determine the scientific defensibility of proposed
criteria modifications.
According to officials with EPA's Water Quality Standards Program, the
agency agrees with our recommendations, has taken some steps to address
them, and is planning additional action. They note that, thus far, EPA
staff have already met with a large number of states to identify
difficulties the states face when attempting to modify their designated
uses. The officials also noted that, among other things, they plan to
release support materials to the states regarding designated use
changes; develop a Web page that provides examples of approved use
changes; and develop a strategy for developing sedimentation criteria
by the end of 2003.
Mr. Chairman, this completes my prepared statement. I would be happy to
respond to any questions you or other members of the Subcommittee may
have at this time.
Contact and Acknowledgments:
For further information, please contact John B. Stephenson at (202)
512-3841. Individuals making key contributions to this testimony
included Steve Elstein and Barbara Patterson. Other contributors
included Leah DeWolf, Laura Gatz, Emmy Rhine, Katheryn Summers, and
Michelle K. Treistman.
FOOTNOTES
[1] U.S. General Accounting Office, Water Quality: Improved EPA
Guidance and Support Can Help States Develop Standards That Better
Target Cleanup Efforts, GAO-03-308 (Washington, D.C.: Jan. 30, 2003).
[2] National Research Council, Assessing the TMDL Approach to Water
Quality Management (Wash., D.C.: 2001)
[3] Specifically, when asked to identify the top three such pollutants,
the pollutants most frequently cited were nutrients, followed by
sediment and pathogens.
[4] Point source discharges include discrete discharges from individual
facilities, such as factories and wastewater treatment plants. Nonpoint
sources of pollution are diffuse sources that include a variety of
land-based activities, such as timber harvesting, agriculture, and
urban development.
