N ovember 2 0 0 0 • V olume 2 • N umber 6 - American Water ...

THE NEW WATERSHED TOOLS:
GENUINE STEEL OR CHROME-PLATED PLASTIC?
Richard A. Halpern
Water resources professionals – especially in the academic
and regulatory communities – are eager to deploy
watershed management tools newly developed in the past
two decades – tools like predictive modeling, rainfall simulation,
and rotational basin-monitoring. Empowered by
a recent federal rulemaking that officially entrusts the
nation's water quality to their “professional judgment,”
they are packing their toolkits, heading into the field (or
at least to the office cubicle), and pushing ahead with
sweeping measures to improve the nation’s water quality.
It started with the Chesapeake Bay 15 years ago, but
now the targets are growing ever larger. The Gulf of Mexico
and its Mississippi River watershed, and indeedthrough
the new TMDL rule published this year (see
Bonner Cohen’s article, this issue), every watershed in
the country can theoretically be managed by these new
tools – affecting millions of American families and, perhaps,
changing how they live. Because such management
decisions will have far-reaching effects on real people,
every water resource professional has an ethical obligation,
I believe, to assess fairly what these tools can and
cannot legitimately do. We should consider seriously
whether the tools in this “toolkit” are the
real thing – fashioned from the steel of reliable
data and sound science – or whether
they are, perhaps, something less – less
worthy of the trust and authority we seem
eager to give them?
These concerns are not merely academic.
The July 2000 issue of IMPACT, ("Long
Term Water Data") emphasized convincingly
that high-quality long-term monitoring is
not only desirable but necessary to making
sound judgments on water, air, and climate
issues. The same issue focused on the dangers of extrapolation
and generalization from limited or localized data,
and lamented not only the lack of long-term data but the
continuing loss of long-term monitoring stations (Slaughter,
2000; Slaughter and Richardson, 2000; Redmond,
2000; Norris, 2000). The quality of our data has a direct
and inescapable bearing on the quality of our policy and
management decisions. The “Garbage In/Garbage Out”
rule is as unimpeachable now as ever. Yet is becoming an
inescapable conclusion that the definition of what constitutes
“garbage” is rapidly changing, and that, in some
cases, researchers are deciding that garbage doesn’t
stink after all.
WISH LISTS AND FABRICATIONS
Congressional hearings this spring on EPA's TMDL
rule made incontestably clear that the nation’s water
. . . the temptation
to pass off a fallible
model as a reliable
representation of
reality is great and
not always resisted
quality databases are desperately inadequate – something
that most water resource professionals have long
known. A Virginia POTW official testifying on behalf of the
Association of Metropolitan Sewerage Agencies (AMSA)
reported that many states’ water quality standards and
criteria “were established in the1960s and early 1970s
without much scientific analysis.” In essence, he said,
they were “wish lists” that “don’t make any sense” in the
current regulatory environment (LeBlanc, 2000).
An exhaustive state-by-state study by the General
Accounting Office (GAO) also presented to Congress this
spring during the Clean Water Act hearings found that,
at most, ten percent of the nation’s rivers have ever been
sampled, even once. A much smaller percentage has, in
fact, been monitored on a long-term basis for multiple parameters.
Only one state in the nation claimed to have
significantly more than half the data needed to make a
sound assessment of its waters. Many states reported
that their 305 (b) water quality reports are based on outdated
assessments, anecdotal evidence, and random observations.
In fact, some reported that the EPA even encourages
them to pad their impaired waters lists. The
GAO also noted that “considerable subjectivity” is unavoidable
in assessments based on “best
professional judgment.” While such an assessment
may be a “reasonable guess,” one
state official told GAO, it nonetheless represents
“a subjective process,” by which incomplete
or nonexistent data can lead to scientifically
indefensible management decisions.
Most disturbingly, state water officials
told GAO investigators that, overall,
less resources are being devoted to monitoring
and assessment at the state level than
ever before (Guerrero, 2000).
SINS OF OMISSION
The States, however, are not the only ones failing to
monitor water quality accurately and adequately. The
Federal government’s record is disastrous. Debra Knopman,
formerly chief of the USGS systems analysis branch
for water resources, likens the Federal monitoring system
to “controlling the heat and air conditioning in a 50-room
mansion with one cheap thermostat” (Knopman, 1997).
The entire Federal monitoring record at Point of Rocks,
Maryland – the confluence of the Shenandoah and Potomac
Rivers – covers the period 1974 through 1989, yet
contains only a single value for total nitrogen concentration
(.73 parts per million) dated August 31, 1976. Yet
USGS’s official published data erroneously indicate a median
concentration of total nitrogen of 2.3 parts per million
based on record of 90 samples taken between 1969
Volume 2 • Number 6 Water Resources IMPACT • 23