made in the context of an integrated planning process, such as Integrated Coastal Management (ICM).

Overcontrol is particularly likely along the ocean coasts, where dispersion of partially treated wastes in deep ocean water may produce few, if any, adverse effects. Nevertheless, full secondary treatment is required in every such case, regardless of cost or lack of benefits. For a time, such issues could be addressed in the waiver process provided in Section 301(h) of the Clean Water Act, but the provision to apply for an initial waiver expired at the end of 1982. Dischargers who have a waiver can request a renewal. Some initial applications are still pending.

An example of undercontrol is provided by the case of Long Island Sound. Despite major improvements in treatment of municipal wastewater, the sound continues to experience hypoxia in the summer because of marine algae blooms caused by nitrogen enrichment. Contributions of nitrogen to the sound come from varied sources. While an estimated 28 percent of the nitrogen input comes from sewage treatment plants discharging directly into the sound, the remaining 72 percent comes from widespread point and nonpoint sources, some of which are upstream of the sound (LISS 1990).

Those sewage treatment plants discharging to the sound and not yet at full secondary treatment are taking action to complete upgrades to full secondary treatment and some are adding nitrogen removal technology. Nevertheless, under the most optimistic projections, plants with nitrogen removal capability will control only three-quarters of their current nitrogen input and only one-fifth of the total input to the sound. Therefore, in the absence of controls for the other nitrogen sources, the hypoxia problems, while decreased, will not be eliminated by the future actions of the POTWs discharging directly into the sound. An integrated nitrogen management plan that manages all sources is envisioned in the Long Island Sound Study (LISS 1990). Such a plan must be fully implemented to solve the hypoxia problem.

Long Island Sound is, therefore, a case of good news and bad news. The bad news is that the original national technology-based, end-of-pipe approach of the 1972 Clean Water Act will leave the hypoxia problems of the sound unresolved. The good news is that the trend toward future collaborative efforts of the states, counties, and cities to address nitrogen enrichment holistically indicate a great potential for success. The promise of an integrated approach to solving the hypoxia problem of Long Island Sound provides a model for a national approach to water quality objectives during the third decade of the Clean Water Act.

Other cases of undercontrol can be found throughout the country. Overcontrol is less easy to demonstrate, since the necessary value judgements have usually not been made. Also, water quality conditions in the absence of some part of existing or improved treatment are sometimes not known with



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