Attaining the Unattainable

A large figure in the world water quality policy weighed in on North Carolina’s current management paradigm. In a blog post, Ken Reckhow rejects some of the fanciful directions recently taken recently by the NC legislature to address impairments in Jordan and Falls lake but acknowledges that clean-up goals for these lakes may be unattainable. So, what should be the goal if the water quality standard is not achievable?

Mr. Reckhow summarizes his opinion:

“I believe that many surface water quality criteria that have been established by the States are not adequately representative of designated use. Further, I believe that in many situations we have set water quality criteria that have resulted in TMDLs that have associated costs of compliance that are way beyond expected water quality benefits. At the same time, I am not a proponent of in-lake treatment processes as an alternative to watershed pollutant load reduction except in small waterbodies where studies have demonstrated the effectiveness of in-lake techniques. My bottom-line perspective on the two issues that I raise – we should revisit the TMDL program and the underlying surface water quality standards, yet we should not be taken in by the low-cost, but ineffective in-lake treatment technologies”

The EPA allows for site-specific water quality criteria. Pursuing that direction would require the State to determine the uses that should be supported by different parts of a lake or estuary and, conceivably, have different standards for those parts.  That may be a direction the State pursues but they should build upon its existing efforts and learn from other nutrient strategies like that for the Chesapeake Bay so that they do not end up recreating the wheel.

Are site specific standards the way to achieve what has been considered unattainable?  Maybe.  Particularly for the Falls Lake nutrient strategy where reduction goals of 40% nitrogen and 77% phosphorus may not be realistic.