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2

Conceptual Foundations for Water Quality Management

This chapter describes the analytical and related policy challenges of implementing an ambient-focused water quality management program, of which the Total Maximum Daily Load (TMDL) program is an example 1. The goal of an ambient water quality management program is to measure the condition of a waterbody and then determine whether that waterbody is meeting water quality standards. By definition, this process is dependent on the setting of appropriate water quality standards. Although realistic standard setting must account for watershed (hydrologic, ecological, and land use) conditions, the corresponding need to make policy decisions in setting standards must also be recognized. In addition, ambient-based water quality management requires decision-making under uncertainty because the possibility for making assessment errors is always present. Properly executed statistical procedures can identify the magnitude and direction of the possible errors so that knowledge can be incorporated into the decisions made. In addition to uncertainties inherent in measuring the attainment of water quality standards, there are uncertainties in results from models used to determine sources of pollution, to allocate pollutant loads, and to predict the effectiveness of implementation actions on attainment of a standard. As part of the information needed in the TMDL program, this uncertainty must be understood and addressed as implementation decisions are made.

AMBIENT WATER QUALITY STANDARDS

Unlike an effluent standard, an ambient water quality standard ap-



1 Although this discussion refers to the TMDL program, it is not meant to be a description of that program.



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Page 22 2 Conceptual Foundations for Water Quality Management This chapter describes the analytical and related policy challenges of implementing an ambient-focused water quality management program, of which the Total Maximum Daily Load (TMDL) program is an example 1 . The goal of an ambient water quality management program is to measure the condition of a waterbody and then determine whether that waterbody is meeting water quality standards. By definition, this process is dependent on the setting of appropriate water quality standards. Although realistic standard setting must account for watershed (hydrologic, ecological, and land use) conditions, the corresponding need to make policy decisions in setting standards must also be recognized. In addition, ambient-based water quality management requires decision-making under uncertainty because the possibility for making assessment errors is always present. Properly executed statistical procedures can identify the magnitude and direction of the possible errors so that knowledge can be incorporated into the decisions made. In addition to uncertainties inherent in measuring the attainment of water quality standards, there are uncertainties in results from models used to determine sources of pollution, to allocate pollutant loads, and to predict the effectiveness of implementation actions on attainment of a standard. As part of the information needed in the TMDL program, this uncertainty must be understood and addressed as implementation decisions are made. AMBIENT WATER QUALITY STANDARDS Unlike an effluent standard, an ambient water quality standard ap- 1 Although this discussion refers to the TMDL program, it is not meant to be a description of that program.

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Page 23 plies to a specific spatial area—a defined waterbody—and is expected to be met over all areas of that waterbody. Thus, identifying the waterbody of interest, whether a lake, a stream segment, or areas of an estuary, is a first step in setting water quality standards. Waterbodies vary greatly in size—for example, from a small area such as a mixing zone below a point source discharge on a river to an estuary formed by a major river discharge. Water quality standards themselves consist of two parts: a specific desired use appropriate to the waterbody, termed a designated use, and a criterion that can be measured to establish whether the designated use is being achieved. Barriers to achieving the designated use are the presence of pollutants and hydrologic and geomorphic alterations to the waterbody or watershed. Appropriate Designated Uses A designated use describes the goal of the water quality standard. For example, a designated use of human contact recreation should protect humans from exposure to microbial pathogens while swimming, wading, or boating. Other uses include those designed to protect humans and wildlife from consuming harmful substances in water, fish, and shell-fish. Aquatic life uses are intended to promote the protection and propagation of fish, shellfish, and wildlife resources. A designated use is stated in a written, qualitative form, but the description should be as specific as possible. Thus, more detail than “recreational support” or “aquatic life support” is needed. The general “fishable” and “swimmable” goals of the Clean Water Act constitute the beginning, rather than the end, of appropriate use designation. For example, a sufficiently detailed designated use might distinguish between beach use, primary water contact recreation, and secondary water contact recreation 2 . Similarly, rather than stating that the waterbody needs to be “fishable,” the designated use would ideally describe whether the water 2 These uses are defined differently from state to state. In Ohio, primary contact recreation includes full body immersion activities such as swimming, canoeing, and boating. Such streams or rivers must have a depth of at least 1 meter. Secondary contact recreation includes activities such as wading, but where full body immersion is not practical because of depth limitations. The fecal bacteria criteria are less stringent for secondary contact recreation than for primary contact recreation.

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Page 24body is expected to support a desired fish population (e.g., salmon, trout, or bass) and the relative invertebrate or other biological communities necessary to support that population. Although small headwater streams may have aesthetic values, they may not have the ability to support extensive recreational uses themselves (i. e., be “fishable” or “swimmable”). However, their condition may have an influence on the ability of a downstream area to achieve a particular designated use. In this case, the designated use for the smaller waterbody may be defined in terms of the achievement of the designated use of the larger downstream waterbody (as illustrated in the discussion of criteria below). In many areas of the United States, human activities have radically altered the landscape and aquatic ecosystems, such that an appropriate designated use may not necessarily be the aquatic life condition that was present in a watershed's predisturbance condition, which may be unattainable. For example, a reproducing trout fishery in downtown Washington, D.C., may be desired, but may not be attainable because of the development history of the area or the altered hydrologic regime of the waterbody. Similarly, designating an area near the outfall of a sewage treatment plant for shellfish harvesting may be desired, but health considerations would designate it as a restricted shellfish harvest water. Furthermore, there may be a conscious decision to establish a designated use that would not have existed in the predisturbance condition. For example, construction of a lake for a warm water fishery is a use possible only as a result of human intervention. Appropriate use designation for a state's waterbodies is a policy decision that can be informed by technical analysis. However, a final selection will reflect a social consensus made in consideration of the current condition of the watershed, its predisturbance condition, the advantages derived from a certain designated use, and the costs of achieving the designated use. Ideally, a statewide water quality management program should establish a detailed gradient of use designations for waterbodies. Box 2-1 describes the multiple tiers of designated uses developed for waters in Ohio. Defining a Criterion A water quality standard includes a criterion representing the condition of the waterbody that supports the designated use. Thus, the designated use is a description of a desired endpoint for the waterbody, and the criterion is a measurable indicator that is a surrogate for use attainment.

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Page 25 BOX 2-1 Appropriate Designated Uses: The Ohio Example An approach to setting appropriately stratified or tiered designated uses for a state's waterbodies has been developed in Ohio. The state recognized early on that a stratified set of use designations for aquatic life, recreation, and water supply was needed to accurately reflect the potential quality of various waterbodies and to guide cost-effective expenditures for pollution controls and other restoration activities. In lieu of general use, more detailed designated uses were developed that reflect the “potential” of the aquatic ecosystem and account for the historical influence of broad-scale socioeconomic activities. Individual waterbodies are assigned the appropriate designated use based on a use attainability analysis (UAA) process that relies heavily on site-specific information about the waterbody. The information used in this process results from the systematic monitoring of waters via a rotating basin approach in which biological, chemical, and physical data are collected and analyzed. Aquatic life uses are based primarily on the biological criteria and physical habitat assessments that are calibrated with regard to the important regional and watershed-specific variables that determine the potentially sustainable aquatic assemblage. Recreational uses are designated based on the size of the waterbody, reflecting the ability of humans to use the water for swimming, boating, fishing, or wading. The system of tiered aquatic life and recreational uses in the Ohio water quality standards was established in 1978, well before biological criteria were adopted for use (May 1990). Two newly proposed uses are now under study: one for urban streams, which would require a sitespecific UAA, and one for primary headwater streams (<1 sq. mi. drainage area), which are outside of the practical resolution of the present biological criteria. (A readily accessible and detailed example of such designated uses for Ohio can be found at http://www.epa.state.oh.us/dsw/rules/3745-1.html. The criterion may be positioned at any point in the causal chain of squares shown in Figure 2-1. Criteria in squares 2 and 3 are possible measures of ambient water quality condition. Square 2 includes measures of a water quality parameter such as dissolved oxygen (DO), pH, nitrogen concentration, suspended sediment, or temperature. Criteria closer to the designated use (e.g., square 3) include measures such as the condition of the algal community (chlorophyll a), a comprehensive index

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Page 26 ~ enlarge ~ FIGURE 2-1 Types of water quality criteria and their position relative to designated uses. measure of the biological community as a whole, or a measure of contaminant concentration in fish tissue. In square 1, where the criterion is farther from the designated use, are measures of the pollutant discharge from a treatment plant (e.g., biological oxygen demand, NH3, pathogens, suspended sediments) or the amount of a pollutant entering the edge of a stream from runoff. A criterion at this position is referred to as an effluent standard. Finally, square 4 represents criteria that are associated with sources of pollution other than pollutants. These criteria might include measures such as flow timing and pattern (a hydrologic criterion), abundance of nonindigenous taxa, some quantification of channel modification (e.g., decrease in sinuosity), etc.

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Page 27 Because the designated use is stated in written and qualitative terms, the challenge is to logically relate the criterion to the designated use. Establishing this relationship is easier as the criterion moves closer to the designated use ( Figure 2-1). In addition, the more precise the statement of the designated use, the more accurate the criterion will be as an indicator of that use. For example, the criterion of fecal coliform count may be used for determining if the use of water contact recreation is achieved, and the fecal count criterion may differ among waterbodies that have primary versus secondary water contact as their designated use. Surrogate variables often are selected for use as criteria because they are easy to measure. Although the surrogate may have this appealing attribute, its usefulness can be limited if it cannot be logically related to a designated use. For example, chlorophyll a has been chosen as a biocriterion in some states because it is a surrogate for aesthetic conditions or the status of the larger aquatic ecosystem. In North Carolina, the ambient water quality standard of 40 µg/l for chlorophyll a was proposed for lakes, reservoirs, sounds, estuaries, and other slow-moving waters not designated as trout waters. However, a discussion of the appropriate designated uses for the waters of the state and how this criterion is logically related to those uses did not accompany the adoption of this criterion. As with setting designated uses, the relationship among waterbodies and segments must be considered when determining criteria. For example, where a segment of a waterbody is designated as a mixing zone for a discharge, the criterion adopted should assure that the mixing zone use will not affect the attainment of the uses designated for the surrounding waterbody. In a similar vein, the desired condition of a small headwater stream may need to be chosen as it relates to other waterbodies in the watershed. Thus, an ambient nutrient criterion may be set in a small headwater stream to secure a designated use in a downstream estuary, even if there are no localized effects of the nutrients in the small headwater stream. Conversely, a higher fecal coliform criterion that supports only secondary contact recreation may be warranted for a waterbody with little likelihood of being a recreational resource—if the fecal load dissipates before the flow reaches an area designated for primary contact recreation.

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Page 28 DECISION UNCERTAINTY Ambient-focused water quality management requires one to ask whether the designated use is being attained and, if not, the reasons for nonattainment and how the situation can be remedied. Neither of these questions, which make reference to the chosen criteria, can be answered with complete certainty. Determining use attainment requires making criterion measurements at different locations in the waterbody and at different times and comparing the measurements to the standard. Individual measurements of a single criterion constitute a sample, and statistical inference procedures use the sample data to test hypotheses about whether the actual condition in the water meets the criterion. Errors of inference are always possible in statistically valid hypothesis testing. It is possible to falsely conclude that a criterion is not being met when it is. It is also possible to conclude that a criterion is being met when in fact it is being violated. Chapter 3 includes recommendations for controlling and managing such uncertainty. Water quality management also requires models to relate the criterion to activities that might control pollution. For example, a criterion requiring a certain DO level may be chosen to help meet the designated use of a trout fishery. Models will be required to relate a management practice, such as fertilizer control, to the DO criterion. These types of models can be broadly labeled as models that relate stressors (sources of pollutants and pollution) to responses—similar to models used in hazardous waste risk assessment and many other fields. Stressors include human activities likely to cause impairment, such as the presence of impervious surfaces in a watershed, cultivation of fields too close to the stream, over-irrigation of crops with resulting polluted return flows, the discharge of domestic and industrial effluent into waterbodies, dams and other channelization, introduction of nonindigenous taxa, and overharvesting of fishes. Indirect effects of humans include the clearing of natural vegetation in uplands that alters the rates of delivery of water and sediment to stream channels. A careful review of direct and indirect effects of human activities suggests five major classes of environmental stressors: alterations in physical habitat, modifications in the seasonal flow of water, changes in the food base of the system, changes in interactions within the stream biota, and release of contaminants (conventional pollutants) (Karr, 1990; NRC, 1992). The presence of one of more of these in a landscape may be responsible for changes in a waterbody that result in failure to attain a designated use. Ideally, models designed to protect or restore water

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Page 29 quality to ensure attainment of designated uses should include all five classes of pollution. The broad-based approach implicit in these five features is more likely to solve water resource problems because it requires a more integrative diagnosis of the cause of degradation (NRC, 1992). Models that relate stressors to responses can be of varying levels of complexity ( Chapter 4). Sometimes, models are simple conceptual depictions of the relationships among important variables and indicators of those variables, such as the statement “human activities in a watershed affect water quality including the condition of the river biota.” More complicated models can be used to make predictions about the assimilative capacity of a waterbody, the movement of a pollutant from various point and nonpoint sources through a watershed, or the effectiveness of certain best management practices. There are two significant sources of uncertainty in any water quality management program: epistemic and aleatory uncertainty (Stewart, 2000). Epistemic uncertainty—incomplete knowledge or lack of sufficient data to estimate probabilities—is a by-product of our reliance on models that relate sources of pollution to human health and biological responses. We are limited by incomplete conceptual understanding of the systems under study, by models that are necessarily simplified representations of the complexity of the natural and socioeconomic systems, as well as by limited data for testing hypotheses and/or simulating the systems. Limited conceptual understanding leads to parameter uncertainty. For example, at present there is scientific uncertainty about the parameters that can represent the fate and transfer of pollutants through watersheds and waterbodies. It is plausible to argue that more complete data and more work on model development can reduce epistemic uncertainty. Thus, a goal of water quality management should be to increase the availability of data, improve its reliability, and advance our modeling capabilities. Indeed, Chapter 4 describes ways in which improved data and modeling can narrow the band of uncertainty and ways to characterize the remaining uncertainty. However, complete certainty in support of water quality management decisions cannot be achieved because of aleatory uncertainty—the inherent variability of natural processes. Aleatory uncertainty arises in systems characterized by randomness. For example, if a pair of dice is thrown, the outcome can be predicted to be between 2 and 12, although the exact outcome cannot be predicted. The example of the dice toss represents the best-case scenario of a system characterized by random

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Page 30 ness, because it is a closed system in which we have complete confidence that the result will be between 2 and 12. Not only are waterbodies, watersheds, and their inhabitants characterized by randomness, but they are also open systems in which we cannot know in advance what the boundaries of possible biological outcomes will be. Thus, uncertainty is a reality that water quality management must recognize and strive to assess and reduce when possible. It derives from the need to use models that relate actions taken to alter the stressors so that the desired criterion and designated use of a waterbody will be secured. Although the purpose of water quality modeling will change depending on how close to the designated use the criterion is positioned, the importance of modeling and the inevitable uncertainties of model results remain. CONCLUSIONS AND RECOMMENDATIONS The two major themes of this chapter represent areas in water quality management where science and public policy intersect. First, with respect to the setting of water quality standards, in order for designated uses to reflect the range of scientific information and social desires for water quality, there must be substantial stratification and refinement of designated uses. Information from science can and must be part of this process; however, there are unavoidable social and economic decisions to be made about the desired state for each waterbody. Second, although science should be one cornerstone of the program, an unwarranted search for scientific certainty is detrimental to the water quality management needs of the nation. Recognition of uncertainty and creative ways to make decisions under such uncertainty should be built into water quality management policy, as discussed in the remaining chapters. 1. Assigning tiered designated uses is an essential step in setting water quality standards. Clean Water Act goals (e.g., “fishable,” “swimmable”) are too broad to be operational as statements of designated use. However, designated uses will still remain narrative statements. 2. Once designated uses are defined, the criterion chosen to measure use attainment should be logically linked to the designated use. The criterion can be positioned anywhere along the causal chain connecting stressors (sources of pollution) to biological response. As the

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Page 31 designated uses are expressed with more detail and are appropriately tiered, the criterion can be more readily related to the use. However, criteria should not be adopted based solely on the ease of measurement in making this link. 3. Expectations for the contribution of “science” to water quality management need to be tempered by an understanding that uncertainty cannot be eliminated. In both the assessment and planning processes, even the best available tools cannot banish uncertainty stemming from the variability of natural systems. REFERENCES Karr, J. R. 1990 . Bioassessment and Non-Point Source Pollution: An Overview. Pages 4-1 to 4-18 in Second National Symposium on Water Quality Assessment. Washington, DC : EPA Office of Water . National Research Council (NRC). 1992 . Restoration of Aquatic Ecosystems. Washington, DC : National Academy Press . Stewart, T. R. 2000 . Uncertainty, judgment, and error in prediction. In Prediction: Science, Decision Making, and the Future of Nature. D. Sarewitz, R. A. Pielke Jr., and R. Byerly Jr., eds. Washington, DC : Island Press .