Bacon's Rebellion

Politics and the Chesapeake Bay – Part 1

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by

James A. Bacon
in

Overview –

This is the first in a series of articles about politics and the Chesapeake Bay. While I’d love to present the matter in one article, the topic is simply too broad and complex for a single post.

In the Beginning – The Chesapeake Bay was formed 18,000 years ago when the glaciers melted and flooded the Susquehanna River valley. 12,000 years ago, mastodons, bison, caribou and mammoths roamed what is now the Chesapeake Bay watershed. 11,000 years ago North American Indians occupied the Chesapeake Bay area. 3,000 years ago the bay reached roughly its present area and boundaries.
Size and scale – 200 miles long and 35 miles wide at its widest point, the Chesapeake Bay is one of America’s largest bodies of water. The bay and its tributaries occupy 4,500 square miles or 41 million acres. The 18 trillion gallons of water in the bay form 11,700 miles of shoreline. Half the bay’s water is supplied by 150 rivers and creeks which drain from a watershed that spans 64,000 square miles. Despite its impressive size the Chesapeake Bay is shallow – averaging only 21 feet deep.
Physical forces – The Chesapeake is extremely complex and ever changing. Water temperature and flow change with the seasons. Salinity varies widely from oceanic levels at the mouth to nearly freshwater levels in the upper tributaries. These are apparent forces. Yet there are less obvious forces at play as well. For example, salinity varies by depth across much of the bay. The lighter fresher water floats to the top of the bay and flows to the sea while the heavier, saltier water collects toward the bottom and flows north from the Atlantic with the tide.
Potential – The extent of the Chesapeake Bay tragedy can only be understood in the context of its present state vs. its potential. That potential is well portrayed in the results of a single hunting party from 1760. The party kills 111 bison, 18 black bear, 114 bobcats, 98 deer, 2 elk, 112 foxes, 109 gray wolves, 41 mountain lions and 500 other unidentified mammals (Source: Chesapeake Bay Blues, page 11, citing Steadman 2001, 99). The Chesapeake Bay Foundation released its annual health index for the bay in 2010. The foundation rated the bay’s health as 31 out of a potential 100. Stunningly, that rating represents a substantial increase over 2009’s rating of 28.
Next Article: A History of Chesapeake Bay Pollution

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37 responses to “Politics and the Chesapeake Bay – Part 1”

  1. Larry G Avatar
    Larry G

    Groveton – Kudos!

    I like the approach of starting out with the facts as a foundation for the follow-on.

    So here's my question.

    We are told that the Chesapeake Bay is a UNIQUE National Treasure.

    How many bays and estuaries are there are there along the coastline of the United States and how do they compare to the Chesapeake Bay in size, habitat, etc.

    For instance, what other bays and estuaries in the U.S. have vital crab and oyster fisheries?

    What really differentiates the Chesapeake from these other Bays and Estuaries that makes it worthy of special national attention and priority?

    Again – Thank you Groveton!

  2. Hydra Avatar
    Hydra

    Excellent.

    However, it wasnt always shallow. Ocean going ships used to go into port tobacco, where you can barely navigate a canoe today. There was deep water on the Potamac all the way to Georgetown. Huge areas have been made more shallow by massive siltation.

    At the same time, the Bay in general is growing deeper as the sea level continuse to rise and the land mass continues to subside.

    Sharpes Island sas a large land mass in early maps and Sharpes Island Light was originally built on shore. Now it is surrounded by more than three feet of water.

    For the last 6 to 8 thousand years the sea level has been rising about six inches to a foot in a hundred years. At the end of the last ice age, it would have been a typical network of more or less V shaped river valleys, and its present shallow contour is the result of 10,000 years of natural siltation and 300 years of man made siltaton.

    What we see as sea level is really a RELATIVE sea level which is the result of sea level rise, land subsidence, erosion and siltation. for the most part this is made apparent in an increase of te size of the mud flats over the years. They tend to maintain a constant epth beneath the surface, and so as silt it added it spreads out in two directions.

    Silt beds near Havre de Grace have een measured at more than 130 feet deep, and it can be shown that much of this came from Pennsylvania soils. In fact, parts of Pennsylvania reported losing substantiall all of their topsoil with fifty years after the initiation of large scale agriculture.

    There is nothing like the Chesapeake anywhere. Most of the largest cities in the world are located on estuaries, but they are of many types. The St Lawrence is larger, but because of its cold water, the ecology is completely different. Only the Ro de La Plata, The Amazon, and some Chinese rivers are anything like the Chesapeake, And it probably equals the sum of all the other east Coast estuaries, with the exception of the Hudson.

    Estuaries are naturally eutrophic, and naturally prone to collect sedment. Indeed, some are formed throught the creation of offshore bars of sediment. human activitie increases these natural processes.

    In order to do what really needs to be done for the Bay, it will have to be elevated to the status of a religion, and billions of dollars of activity would have to be banned from its watershed.

    That is not going to happen, and as a result some or even much of the value of the Chesapeake will be its continued use as a sewer.

  3. RBV Avatar
    RBV

    Looking forward to this series Groveton.

    There is so much information and he said/she said in regards to the state of The Bay (and who's to blame) it's hard to know where to start.

    Anyway, what differentiates the Chesapeake Bay from others is that it is THE LARGEST estuary in the United States.

    Estuary's are transition zones between fresh water and salt water environments.

    Among other things, the Chesapeake Bay is to VA/MD what the Grand Canyon is to Arizona or the Everglades are to Florida, or the Rain Forests are to Brazil.

    It's health is important for economic and environmental reasons.

  4. Hydra Avatar
    Hydra

    Yeah, I can't wait to see the property rights history of the Bay.

  5. Larry G Avatar
    Larry G

    Is the Chesapeake Bay substantially different from the effects of development and siltation than other estuaries and bays in the U.S.?

    why? why not?

  6. Larry G Avatar
    Larry G

    how many significant bays and estuaries are there in the U.S. ?

    If we were going to rank the top 3 or top 5 estuaries in the U.S. what would they be and would they all be facing the same issues as the Chesapeake Bay or not?

    why? why not?

    Don't get me wrong.

    I'm not doubting the importance of the Chesapeake Bay nor the issue it faces but I'm looking for some context and contrast.

    If you grab a map of the U.S. and follow the coastline – you'll see many bays and estuaries.

    I note that they have oyster beds in Long Island Sound, for instance, considered a very valuable fishery.

  7. RBV Avatar
    RBV

    Larry –

    I am not an expert but I will take a stab at it.

    I think what makes The Bay so unique is not just the amount of shoreline it contains but the size of its watershed which is all the rivers, streams, creeks, etc., that end up flowing into The Bay in one way or another.

    Just google "Chesapeake Bay Watershed" and look at some of the maps.

    So, "Is the Chesapeake Bay substantially different from the effects of development and siltation than other estuaries and bays in the U.S.?"

    I would say yes it is simply because of the size of it's watershed.

  8. Hydra Avatar
    Hydra

    There are two significant ones. Chesapeak Bay, San Francisco Bay (which is an entire dfferent creature)

    After that you have the Hudson river, Delaware river, The Cooper river In Charleston, (All tiny compared to the Bay) and a bunch of small stuff that wouldn't amount to a creek in the Chesapeake.

    It is unique. There is nothing else like it, Anywhere.

    They all have similar problems but the scope is different. The hudson River has far more Flushing action.

    Delaware Bay has more flushing and more sloshing because the embayment is different and smaller.

    If you added up everything that ends up on the bottom of every estuary on the east coast, I doubt if it would add up to what lands in the Chesapeake.

    There is no ranking the top 3 or five. It is basically CB and then everything else. The only thing close is Long Island Sound, which has a number of rivers emptying into it, but it is mainly salt water, and it has hydraulic tidal currents.

    However, the western end is heavily impacted by New York, and much marine life has disappeare from that area, similar to dead zones in the Chesapeake. The drainage basin is tiny compared to that of the Chesapeake.

    There is oystering along the Connecticut shore, but my understanding is that most long island oysters are commercially grown in the sounds on the south side of long island.

  9. Larry G Avatar
    Larry G

    there are estuaries and bays all up and down the coastlines of America.

    Get a map out before you say otherwise and carefully follow the coastline and you'll see that there are at least a dozen major estuaries and yes – you CAN RANK THEM.

    And yes you CAN characterize them in terms of topography and flow.

    And yes, you CAN compare and contrast them in terms of land development, runoff problems and pollution.

    The Chesapeake Bay shares many of the same problems that we see in other estuaries and bays in this country – and it's important in trying to understand what is going on in the Chesapeake Bay to see if other estuaries and bays are also suffering in the same way – or not.

    That would be a needed first step in trying to better understand the differences and responses to them in my view.

  10. Hydra Avatar
    Hydra

    There are at least a dozen major estuaries and yes – you CAN RANK THEM.

    No, there are not any othe MAJOR tributaries.

    CB is the third largest in the WORLD. And the other east coast US estuaries are peanuts by any kind of comparison. Even Long Island sound is peanuts, if you count that as an estuary.

    All of them have some charachteristics in common, and most of those derive from the fact of gravity — The estuaries are a sink for everything that happens in their watershed, a sewer, if you will.

    Now we have to decide how clean we want to make our sewers, and how much cleaning we can afford.

    I don't see what your argument is, Larry. If you are arguing that ALL the estuaries should get similar and proportional protection, you are probably correct.

    I would argue that if you are a federal taxpayer in the Cooper watershed, then you deserve as much benefit for your tax dollars as someone in the Chesapeake watershed.

    That said, the proportion is still going overwhelmingly to the Chesapeake Watershed.

  11. Hydra Avatar
    Hydra

    "And yes, you CAN compare and contrast them in terms of land development, runoff problems and pollution."

    ================================

    The correct way to compare them is to determne the highest value for use of the resource.

    This is a distatsteful idea for many, but it could very well be that the most valuable use is fundamentally as a sewer. If that is the case, then you may have to write off the fisheries because their value is minimal compared to the upland development they are preventing.

    I can hear it coming now: how do you put a price on the lives of fish, or avoiding frogs with two heads?

    Well, I would argue, that whatever policy you choose, you will have done just that. The estuaries and the pressures on them ARE enormously different, yet we can compare and contrast them. The same goes for the price and value of fisheries.

    So, if we decide that we wish to put the Chesapeake back into a condition in which the oyster population can filter alll the water in the bay in three days, we can figure out how much that will cost in terms of every bushel of oysters harvested.

    If you then decide that Chesapeake Bay is worth spending environmental money on, at a rate of $3000 per bushel, then you have an obligation to protect other fisheries at the same rate.

    Now suppose you go to the Hudson, spend $3000 a bushel, and discover the oysters are still too poisonous to eat. Then you discover that you can go to the Tiasquam river and resurect oyster fisheries for only $500 a bushel.

    The answer is to save the Tiasquam Oysters first. Then give the monwy you saved to the Hudson oysterers to not fish their poisoned resources. The winners pay off the losers such that everyone is better off.

  12. Larry G Avatar
    Larry G

    The only thing I counsel for the Chesapeake is to recognize that things like development, land-clearing and impervious surfaces is not a unique condition found ONLY in the Chesapeake Bay and it's tributaries.

    Do you think the Chesapeake Bay has more silt, nitrogen, phosphorous, pharmaceuticals, toxics, mercury that the Delaware or Mobile or Rio Grande or Mississippi, Columbia ,Altamaha, etc?

    What is it about the Chesapeake Bay watershed that would make it significantly different from other watersheds?

    Which tributaries of the Chesapeake Bay are the cleanest and least polluted? Which ones are the most polluted and what are the sources of the pollution?

    Does the bay suffer more from farming runoff or urban stormwater runoff?

  13. Larry G Avatar
    Larry G

    re: best use of the Bay.

    They've already done the homework on this.

    It's called TMDL – Total Daily Maximum Load – of pollutants.

  14. Hydra Avatar
    Hydra

    The situation is more or less this. We can measure and identify many kinds of environmental issues, but we can make only the crudest kind of guesses as to what the cost of the damage might ultimately be.

    For the most immediate, most apparent, most advertized, and most known issues we put huge safety margins around them and set about spending enough money to keep out of the danger zone. Often we get the money by suing someone, for doing something that was legal at the time he did it.

    We exert new and retroactive property rights, without paying the retroactive costs. had our (newly hatched, current) polluter known at the time what his costs would be, he would have charged us more for his products, we would have used less, and there would be less pollution today.

    By changing the system boundary retroactively in time, we pretend to avoid our own share of the costs in preventing pollution.

    That is one approach, and the one we have mostly taken. There are two problems with it. The first is that the issues are examined in isolation, and there are many many of them. The costs of staying entirely outside the danger zone for all of them might turn out to be more money and resources than exist. Sort of like Homeland Security.The second problem is that you might be too far outside the danger zone or not far enough, or you might have missed an isue entirely (problem not known yet).

    One alternative is to ignore all the environmental issues, other than to recognize they exist. Instead simply designate a budget you are willing to spend for a better environment. Set a tax on things we use that damage the environment (virtually everything) to raise that much money, maybe that tax is 25%.

    With this approach, it does not matter what the biggest environmental problem is, it matters which are the cheapest to fix, so that you get the most possible fix for your money.

    And now, since the entering argument is that the environemtn belongs to oall of us, there is no argument about where the money gets spent or who benefits. All we know is that whe did the best we could for the money, and any argument for some other spatial allocation results in a lesser overall benefit.

    The difference in in your acceptance these two approaches is determined by whether you are first a fiscal conservative or first an environmental conservationist.

  15. Larry G Avatar
    Larry G

    there is no right to pollute – period. the rivers belong to the public – not property owners and the public decides how much pollution is acceptable.

  16. Hydra Avatar
    Hydra

    It's called TMDL – Total Daily Maximum Load – of pollutants.

    Best use of the bay.

    =================================

    But TMDL is just a standard, and achieving that standard has both a price, and a value.

    The price is how much do I have to spend to clean up after my activities, plus how much I lose from activities prohibited.

    The value is how much are my fishery, recreation, habitat protection, plus the sewer allotment provided by the TMDL worth?

    So now I've got two estuaries and the ratios are Expense1/Value1 and Expense2/Value2. The factor not shown is the TMDL factor, which of course determines the ratios.

    Suppose we consolidate the values into something we call EU's (Environmental units) and that is the weighted average of what is enjoyed by fishermen, kayackers, duck hunters, and manufacturors for the values listed above (and whatever others we discover).

    Now the ratios come down to $ per EU.

    Why should the residents of one estuary pay more per EU than the residents of another? or, why should the users of EU's in one place get their EU's with a higher subsidy than the other?

    Well, because one estuary has more flushing action and the other is more like water sloshing back and forth in a tub, with some loss and some makeup.

    OOPS. Now you have introduced a new variable by changing the system boundaries. One estuary gets a free ride by discharging to the outside world, and the other is stuck with the costs of fouling its own nest.

  17. Hydra Avatar
    Hydra

    there is no right to pollute – period.

    =============================

    I'll beleive that as soonas you stop polluting – period.

  18. Hydra Avatar
    Hydra

    As soon as you create a TMDL, you have effectively created the right to pollute.

    At least I have the same right to bid for the use of the value of pollution provided by the TMDL as you have.

    If there is no right to pollute, there is no need for the TMDL, or we can set it at zero.

  19. Hydra Avatar
    Hydra

    What you are saying now is that you are not a fiscal conservative, but an environmental conservative, money be damned.

  20. Larry G Avatar
    Larry G

    TMDL = WLA + LA + MOS

    http://en.wikipedia.org/wiki/Total_maximum_daily_load

  21. Larry G Avatar
    Larry G

    we all pollute but you do not get to decide as a property owner how much you can pollute or how much others can.

    That right belongs to ALL property owners.

  22. Hydra Avatar
    Hydra

    " the public decides how much pollution is acceptable."

    ==============================

    And when they do that, they put a price on their property. Their EUs, if you will.

  23. Larry G Avatar
    Larry G

    there is no "right" to pollute – only the "right" to seek permission.

  24. Larry G Avatar
    Larry G

    fiscal conservatism means "conserving" and not wasting or destroying – for economic gain – at the expense to others – also.

  25. Larry G Avatar
    Larry G

    putting a price on it does not mean than anyone can according to their own standards.

    It means the public – all property owners – make that decision – and it applies to everyone.

    Just because you own a piece of land or a building does not give you any "right" to pollute.

  26. Hydra Avatar
    Hydra

    You are either going to put a price on it, or you are going to monetize the results as a matter of how you fund the policies you choose.

    I argue that it is better to know the value of the results you seek, so that you do not overprice, and overspend for the policies you choose.

    Failing that, you should know how much you can spend, and at least have some idea of the cost of the results you seek, so that you can prioritize you spending to get the best results for the buck.

    At this time, we may not know the best vbalues, but we have some kind of estimate with some kind of accuracy. We can improve that and narrow the rqnge of uncertainty, once we agree on the general idea.

    You seem to reject the entire idea. No pollution is acceptable, and any cost to prevent it is OK, so long as the polluter pays it.

    This is a stupid, idealistic, and childish idea, than cannot and does not work in actual practice.

    In actual practice, when you make something, you make a mess. some of the mess can be cleaned up, and some cannot. Some has harmful external cost, and some does not.

    It makes no sense to spend $200 to clean up a mess that does $100 worth of damage, whether it is your $200 or not. Such an argument is a waste of resources, and therefore not green. It is also a violation of the golden rule because no one, because no one would want to be forced to pay $200 to prevent every possible $100 in damages.

    It makes no sense for the same reasons to simply ban $100,000 worth of production in order to prevent $100 in damages. It is not fiscally conservative to make such suggestions, and if your definition of fiscal conservatism holds, then you must agree with my analysis becasue its root is simply the goldent rule which simply means you cannot waste or destroy economic gain for others that you ould not willingly give up yourself.

    There is a method by which we determine this: to determine the correct level to set the standards, and that is to let the market determine the costs and the benefits.

    That is never accomplished when one side declares prior advantage or infinite value. Just as a stream has a limit on TMDL, so does the environemtn have a limit on EU's, however we measure them.

    We all own the TMDLS and the EUs, and anyone ought to be allowed to sell his share. Anyone else ought to be allowed to withhold his share and demand a higher price, if he can get it.

    No golden rule problem, and a procedure that is already regularly, but not universally used in the real world.

    Think about it. if everyone is granted an equal share of EU's every year, it would amount to a HUGE wealth transfer from developed nations to undeveloped nations, because we would have to buy from them enough EUs to support our lifestyle.

    With he money they gain, they will want to improve their lifestyle, and thus be less willing to release their EUs.

    This satisfies conservatives who believe in equal opportunity but not equal results, and it satisfies those that think we are opressing the rest of the world, somehow.

    Like you say, everyone has a say inthe standards, even the polluting part of the public. I have no problem with that. The problem I have is that people wish to set standards that infact or in effect only apply to others and only cost others money.

    Only when they can clearly see and pay for the costs the standards they desire will impose, will ou get realistic standards. Otherwise there is no feedbak loop to prevent them from making outlandish demands, like zero pollution and 100% recycling.

  27. Larry G Avatar
    Larry G

    The TMDL actually allocates pollution – as much of it as the river can accommodate without degrading other uses.

    In other words, the concept is that the rivers WILL be USED for a variety of uses and the policy is to ensure a balance so that one kind of use does not deny another kind of use.

    so the policy recognizes that a certain amount of treated sewage will go into the rivers, a certain amount of nitrogen, phosphorous, sediment, e-coli, etc.

    The policy explicitly disavows trying to keep the rivers "pristine" except for certain tributaries that are designated for trout and water supply.

  28. Hydra Avatar
    Hydra

    Agreed. Now how do you decide who gets to use the carrying capacity represented by the tmdl?

    Auction it off, same as we do for the carrying capacity of radio spectrum. As soon as you do that, it becomes property representing a certain right to pollute. The owner can use it to help him make products to sell. If someone else comes along with better management, products, or supply chain, then he can afford to buy the property to make something more valuable.

    Where does the money go?

    Well we all own the environment, we should get the money. Consider the initial auction to be an IPO. The successful bid sets the value of the shares. They can then be bought or sold or held for future appreciation.

    They would represent a separate class of stock in the company that owns the pollution rights. This would give shareholders considerable power over the company. Ordinarily a company could threaten to move. But now they would have to relinquish a valuable asset to do so. Or, if the shareholders wish to boot a company, they could allow a hostile takeover of those rights by another company

  29. Larry G Avatar
    Larry G

    You'll have to read up on TMDL because once they set the limits for a substance for the entire watershed – they then have to go up the watershed to allocate and that is the part that is getting interesting.

    For instance, once they allocate to an activity like the wastewater treatment plants for a region – that's it.

    You get to put X number of pounds in – for your region – not for your population – so if you grow -you have to stay within your fixed allocation limits unless you go through a process called UAAs Use Attainability Analyses.

    Some localities are already asking " what if we run out of water/sewer connections"?

  30. Hydra Avatar
    Hydra

    Yes Larry, I know all that. I was working on TMDL's and putting together protocols for measuring them 40 years ago. I could see the political handwriting on the wall and the path that led to todays position even then.

    TMDLs are going to create a new kind of property, and someone will wind up owning it. Whether it is owned politically, through lobbying, or individually.

    Its practical effect will be, just as you describe, yet another kind of zoning overlay. With enough such layers, we can make the bureaucracy of navigating them, and meeting the mutually contradictiing requirements among them an impassable reef, and nothing will get done.

    It is almost exactly the Scenario explained to me by Supervisor Atherton almost 20 years ago, as the political approach to creeping conservationism, that skates exactly along this side of supreme Court orders.

  31. Hydra Avatar
    Hydra

    Some localities are already asking " what if we run out of water/sewer connections"?

    +++++======================

    Why are they asking that. If TMT and others who think growth doesn't pay are correct, then they should be dancing in the streets.

    Where are we going to put those people we deny sewer connections to?

  32. Larry G Avatar
    Larry G

    I suspect that if one place exhausts their allocations that they can buy others – for a price.

    I'm sure Facquier would gladly sell theirs, eh?

    🙂

  33. Hydra Avatar
    Hydra

    No. It wont work that way because it is site specific. When you run out of capacity you might buy and sell within that designation.

    Much of Fauquiers has probably been given away with the conservation easements.

  34. Andrea Epps Avatar
    Andrea Epps

    I've just read the new TMDL docs from the EPA and the "Plan" that Virginia submitted. I like clean water. I don't want to drink nasty water any more than anyone else, BUT…
    I know of at least one locality who has spent well over 100 million on mandated upgrades to be compliant with current regs by 1.1.11.
    They will tell you that as of 11.29, (issue date for new TMDL…i think) we might as well have burned that money because it will kill the allocation limits, and they can't get another permit ( for something like waste water treatment plants). That's just a local government perspective.
    Hydra, it seems to me you have a particular issue with takings. This one is going to take more than anyone expected. Unintended consequences? Here we go!
    Heck, when the state submitted their plan,(after they edited it so the EPA wouldn't put Virginia on the "watchdog" list) the executive summary was written as a complaint about the EPA.

  35. Larry G Avatar
    Larry G

    I've read the TMDL docs also and while the EPA has set allocations for each river – I cannot see how they did the sub allocations per region and locality.

    That's why I ask – what the allocations are up and down a river because without such allocations how could you go to …say a municipal wastewater treatment plant and has already met their NPDES criteria limits, how would it be justified to tell them to go even lower – without some substantial, evidence-based data?

    I predict – that the procedure known as UAA is going to become a much more well recognized acronym….

    UAA = Use Attainability Analysis

    And this UAA, will become a very lucrative consulting business…. for any locality or any region that challenges any arbitrarily assigned allocation including those that come from computer modelling.

  36. Andrea Epps Avatar
    Andrea Epps

    Hey Larry.
    I'm familiar with analysis similar to UAA…maybe we should start some consulting. 🙂
    There are localities that are going to sue the EPA over this, in addition to any state lawsuits.

  37. Larry G Avatar
    Larry G

    Andrea – well my understanding of the UAA is that a locality would engage a company who either had on staff or under contract the appropriate science-based folks who could go through the numbers but I would think before it got to that point that the locality would be asking DEQ (I assume trying to carry out the EPA approach) to justify the mandated reductions.

    In order to do that – I would assume that DEQ would have to show the elevated conditions downstream of the locality which I then suspect end up with the locality measuring conditions upstream of them to essentially prove that conditions upstream were about the same as downstream and thus their effluent – not the primary cause of the elevated numbers.

    This is the kind of thing that I do not see in the TMDL implementation docs.

    It sounds like the EPA is going to delegate to DEQ – the IMPLEMENTATION of the allocation process and use sanctions to encourage compliance.

    But the way the EPA is going about this – it appears that the sanctions would be put on the State – not the locality.

    And if this is the approach and I hope it is not – but if it is – it's going to end up a huge CF with the State and EPA in court and then EPA itself ultimately becoming the implementing agency.

    See.. one reason I ask about other estuaries – is to ask if there is anywhere else in the entire country where a successful TMDL allocation process for nitrogen and phosphorous has been successful and if so how it was done.

    I've looked and looked and so far not successful in find much about this.

    The best folks on the actual science – as well as actually collecting actual data is the USGS.

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