Politics and the Chesapeake Bay – Part 1(a)

Overview: I have decided to add an unplanned segment to the Politics and the Chesapeake Bay series. I felt there were sufficient questions following the first article in the series (Pt 1) to warrant an intermediary article to answer those questions. The two big areas of interest involved the uniqueness of the Chesapeake Bay (especially as an estuary) and the forces continuing to change the bay (especially rising sea levels).

What is an estuary? It is a partly enclosed body of water with one or more rivers or streams flowing into it. Some definitions add a requirement for brackish water. The bottom line is that there is no completely accepted definition of an estuary. However, like pornography, you know it when you see it. The Chesapeake Bay is unquestionably an estuary. So are both the San Francisco Bay and the St Lawrence River. Other bodies of water, like the Gulf of Mexico, might meet the technical definition of an estuary but wouldn’t qualify in my book.

Is the Chesapeake Bay unique? In many ways, yes. The Chesapeake Bay is not the largest estuary in the world. That distinction belongs to the Rio de la Plata located between Argentina and Uruguay. However, the Chesapeake is the largest estuary in the United States and is generally considered the third largest estuary in the world. Yet even these “facts” can be disputed. By surface area, the largest estuary is Rio de la Plata. By length it is the St Lawrence River. By miles of shoreline it is the Chesapeake Bay. By any measure, the Chesapeake joins a very few other aquatic marvels (such as Florida’s Everglades) as one of America’s most important natural wonders.

The Changing Chesapeake. Anybody who boats on the middle section of the Chesapeake Bay knows Sharp’s Island Lighthouse (pictured in this post). The lighthouse sits at the intersection of the Choptank River and the main bay. It is instantly recognizable by its 20 degree tilt (caused by ice floes during particularly cold winters). The current Sharp’s Island Lighthouse was not the first. The first lighthouse was built in 1837 on top of a 900 acre island which was home to a thriving agricultural community. Named Sharp’s Island after the Quaker physician who once owned it, the island was a beautiful place in the mid 1800s. So beautiful that a wealthy Baltimore shoe manufacturer built a resort hotel on the island. There was only one problem – the island was rapidly sinking into the Chesapeake Bay. The isle (which measured 900 acres in the 17th century) was down to 94 acres by 1900. The island is under 9 to 12 feet of water today.

The rising tide. The water level in the Chesapeake Bay’ along with the rest of the Mid-Atlantic coast’ is rising at twice the rate of sea levels worldwide. This amounts to 1.3 feet per century at the mouth and 1.0 foot per century in mid-bay. That’s a lot of extra water but far from enough to put a hotel that was dry in 1900 under ten feet of water today. The Chesapeake Bay has been identified as one of four anomalous areas along the U.S. East Coast that appear tectonically active. There is a down-warping of the Earth’s crust called the Salisbury embayment. This embayment could certainly be the root cause of the mini-Atlantis known as Sharp’s Island. However, the entire US Mid-Atlantic coast is experiencing sea level increases well beyond global averages. And the Salisbury embayment cannot be blamed for all of that!


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106 responses to “Politics and the Chesapeake Bay – Part 1(a)”

  1. Living In Williamsburg Virginia Avatar
    Living In Williamsburg Virginia

    Interesting info. Whether it's the largest, widest, or has the most shoreline, the Bay is on beautiful body of water.

    Darryl and Ruth : )

  2. Nicely done. And no innumeracy.

  3. Gooze Views Avatar
    Gooze Views

    Interesting stuff, Groveton. When are you going to get to the giant meteor?

    Peter Galuszka

  4. Larry G Avatar

    I agree nicely done but not sure what the point is this post was.

    I just want to continue to point out that while the Chesapeake is the largest estuary in the U.S. that there are quite a few that we take for granted.

    Two down south are called "sounds" – they would be the Albemarle and Pamlico.

    Take a look at a map and you'll see that Pamlico drains a significant portion of Va – extending to Roanoke an actually originates WEST of I-81.

    The Altamaha River drains much of the northern half of Georgia.

    I'm not saying that the Chesapeake Bay is not unique but I am saying that it's uniqueness is not that it is an estuary with a large network of tributary rivers.

    Much of North Carolina drains in a a river called the Pee Dee which drains into Winyah Bay, another significant estuary – in it's own right.

    I could continue this tour of estuaries around the entire perimeter of the U.S.

    Suffice to say – that while the Chesapeake Bay is the largest estuary – so is the mouth of the Mississippi – another vital fishery that we all came to better recognize once it got "oiled".

    Why is it important to recognize that estuaries are common in the U.S.?

    Because unless there is something truly unique about a given estuary – they share many characteristics – including some problems.

    To the real point.

    What makes the Chesapeake Bay's problems – unique?

    And what is it about the "politics" of the Chesapeake Bay that distinguish it from other estuaries in the country?

  5. J. Tyler Ballance Avatar
    J. Tyler Ballance

    Here’s another way for those who want action on environmental issues, to send a message:

    There will be a special election in the 91st House of Delegates district (Hampton-Poquoson-York).

    The filing deadline is January 21, 2011 at 5:00 PM

    The election will be on March 8, 2011.

    The Constitution Party, and the Libertarian Party are both seeking qualified candidates to run.

    If you know anyone in the 91st, who will take positions that will enhance liberty and restrain government, then ask them to run, and volunteer to help.

    See the SBE website: Candidate Bulletins for details.

  6. Larry G Avatar

    Hey Tyler – can you tell us what the position of the Tea Party and Constitutional Party and the candidates they support is on the cleanup of the Chesapeake Bay?

    Shouldn't we know that?

  7. Larry G Avatar

    here's some perspective – food for thought:

    " In the Albemarle basin, the amount of phosphorus in the receiving
    waters is estimated to be about three times the normal background levels, and
    nitrogen i s estimated to be about twice the background levels. "

    http://www.nwrc.usgs.gov/techrpt/83-01.pdf page 56

    Now – does anyone know the comparable concentrations of nitrogen and phosphorous in the Chesapeake Bay and it's major tributaries relative to "background" levels?

    Does anyone know what typical "background" levels are?

    Does anyone know which of the tributaries of the Chesapeake Bay has the HIGHEST concentration of nitrogen and phosphorous?

    How about the LOWEST? Which tributary has the LOWEST concentration?

    What would the rank list look like that would show all the tributaries and their relative contributions?

    Why do I ask these questions?

    To basically illustrate how little most of us know about the facts involved.

    How can we argue the issues and the politics if we don't know the basics?

  8. I have to ask again, Larry, what is your point?

    That all estuaries need help? That the largest one does not need the most help?

    I don't get it.

  9. Larry G Avatar

    The point is – do we really know what the problems are and where they are and what we need to do to address them – and the costs?

    The bottom line is much of the public is truly ignorant on the specifics and as long as all they have to do is say "Save the Bay" – they're ok but at soon as you say they need to fork over a $1000 bucks a year – you're going to see some major opposition.

    No one has truly tried to educate the public on the issue.

    It's at best in most people's minds a ephemeral concept and little more.

    If no one can tell me which river in the Chesapeake Bay has the highest concentrations of nitrogen and phosphorous – it also a pretty safe bet that for any river they also don't know where the concentrations are highest (and need priority attention) and where they are not (and won't need near a much).

    We are, as a public, woefully ignorant beyond the "feel good" idea that "something" needs to be done and I don't think we get to the next step until people understand.

    We'll get something soon from Groveton on the politics and I'll be interested in hearing his take on the issue.

  10. Anonymous Avatar
    Anonymous

    Larry's questions about 'The Bay' are a lot like what is not known about the settlement patterns on the land around 'The Bay.'

    That is because almost all the problems with 'The Bay' are problems that are found on the land around 'The Bay.'

    Settlement pattern dysfunction is a terrible thing from an economic, social and physical perspective — including the pysical impact on 'receiving waters.'

    MGM

  11. Larry G Avatar

    even more than that – at this point – most folks don't even know the proportion of contributions with respect to vacant (undeveloped) land (background concentrations), farmed land, and developed land.

    Most folks don't know the first thing about it.

    Most of us don't know, for instance, whether or not the nitrogen/phosphorous levels are 2, 3, or 4 times or worse normal background levels…

    … how much carrying capacity the rivers and Bay has in terms of higher than background levels…..

    what kinds of things will be necessary to reduce levels both in farming and developed areas …..

    and their costs….

    right now – what we do know is how much is contributed by municipal wastewater pipes…

    …but we don't know how much storm water contributes…

    .. and despite all the blather – we really don't know how much septic tanks contribute….

    much of it right now is a combination of computer model predictions, speculation… and yes.. just plain ignorance….

    We cannot begin to go about figuring out how to proceed until we know the answers to the above questions – not just the scientists – but the public because ultimately – the public will decide if they are willing to pay for the cleanup.

    Right now – the people who live in the urbanized areas – have been convinced that they are not the problem and that the problem is farmers.

    Farmers, are petrified that the government is going to swoop down on them and tell them to cough up 10, 20, 30K or walk away from their land…

    The problems with the Chesapeake Bay and it's cleanup is not the pollution per se – it's the dumbass way we are going about dealing with it.

    GRUMP!

  12. Larry two thirds of nitrogen in the bay comes from cows in pa. It has been the same for decades.

  13. Larry G Avatar

    Ray – show me the data.

  14. Groveton Avatar

    The series will endeavor to answer all the questions being asked in these comments.

  15. Done that before. You didn't believe it last time, either.

  16. as I recall.. you did not provide authentic data… but I'll certainly look again.. if you have something credible.

    Remember, I'm not asking what the percentage of flow into the C-Bay is from the Susquehanna, I'm asking to see if more than the Susquehanna's SHARE – comes from the Susquehanna.

    In other words – is the CONCENTRATION of the nitrogen and phosphorous in the Susquehanna PROVEN to come from farms and not other sources by actual measured data?

    Do you have a reference to the actual measured data?

  17. 38% agricultural, 19% municipal wastewater, 25% airborne deposition from mobile and industrial sources.

    Guess which is easiest and cheapest to fix, not that it is cheap.

    And once you make all that sludge, where do you put it?

    Back on the land.

  18. Susquehannah has both the highest flow and the highest concentration. But even without the highest concentration it would easily have the highest total contribution.

  19. Pa has more than eight times as many cattle as MD.

  20. that doesn't mean a thing.

    what matters is what the concentrations are – in the river BEFORE you think you know where it came from.

    That's the first step.

    You need to know – at the mouth of the river – how much more than the background level the concentration is.

    Then you need to find out WHERE it came from.

    Did it come from Farms or did you come from developed areas?

    Did it come from septic tanks or municipal wastewater discharges ?

    If you decided – rather ignorantly – that the majority of it came from cows and you outlawed the cows but it did not change the nitrogen/phosphorous levels what would you have accomplished other than to cause a lot of economic harm without a shred of evidence to justify it other than your own uninformed, subjective opinion and little else.

    We can decide a policy this way.

    Not only will it not be effective – but it will bankrupt people whose only crime was to be target of ignorant policy makers… and ultimately you totally fail at what you were attempting because the public knows you are a fraud and basically attempting policy based on little more than personal opinions and not evidence.

  21. Unfortunately, one cannot take a hundred gallon sample from the middle of the bay, extract the nitrogen and then examine the nitrogen to see where it came from. And, the sources vary over time. As a result, any composite analysis has to be assembled.

    It is a computer model, if you will. Strangely, the more data points and more samples you have, the more computing is required to produce results.

    Larry's complaint seems to be that despite years of research and thousands of samples, we still don't know enough to adequately ( or fairly) allocate resources to clean up the mess.

    All I can say is that getting an adequate sample profile is an enormous job.

    But it pales in comparison to what the clean up will take.

    Frankly, I believe the cleanup is impossible. Fundamentally, it will require turning the clock back, such that our waste stream is what it was in 1600.

    Even if you could afford to do it, where would you put the waste?

  22. It means eight times as much manure, Larry. There is no way around it.

    Despite what you think, I do not need to measure directly how much nitrogen falls in the bay from power plants in Ohio. Pretty much all I need to know is how much coal was burned. After that, the nitrogen went someplace downwind. The amount fluctuates, but the average is pretty resolute.

  23. Of course, we could argue, that pollution ( congestion of the waters) is only caused by the newcomers, and just charge them water tolls, congestion fees, and proffers.

  24. you cannot know what to cleanup and where unless you take the samples – up and down the river – so you what the concentrations are.

    This is not rocket science.

    The USGS does this right now at their guage sites but those sites only give snapshots at fairly divergent points and you need more measurements.

    If you don't know where the concentrations are – and are not – how can you possibly tell a farmer to do 20K worth of changes or a municipality a million dollar upgrade or a shopping center to put in a million gallon underground storage tank?

    This is the kind of thing that causes huge backlashes from business and ordinary people and gives the cause of "environmentalism" a bad name.

    We need good defensible data that proves where the problems are and are not and a fair way to allocate the costs to remediate – and – most important – to use the same comprehensive network of monitoring stations to KNOW that the efforts are working.

    If you are not going to do this – then the public is never going to accept their responsibilities nor the costs.

    and the entire effort will end up another abject failure.

    this is a simple thing.

    If we are going to do this – we have to do right.

  25. re: " Frankly, I believe the cleanup is impossible. Fundamentally, it will require turning the clock back, such that our waste stream is what it was in 1600."

    That's fundamentally wrong.

    If we took that attitude when the Potomac was a festering cesspool of waste – it would never have gotten cleaner.

    The TMDL's acknowledge that the rivers will never again be pristine and they do not seek that level of cleanup either.

    They've determined how much load the rivers can handle – scientifically – and now we have to determine how to allocate the reductions.

    in order to allocate reductions, you have to know where the higher concentrations are – and are not.

    And where they are – implement changes and where they are not – don't penalize people for nothing.

    The cleanup needs to be based on real evidence and needs to be done equitably and fairly.

    If you do it that way, people will grip – but they can't argue with the actual data.

    Without the actual data – no one is going to accept what a computer model says before or after.

    You just can't go tell some locality to put in 50 million worth of upgrades – double everyone's monthly water bills and then later on tell them that the upgrades needed to be made for stormwater rather than wastewater.

  26. We already know that 38% comes from farms and 4% comes from septic tanks. If both those numbers are wrong by 15%, it doesn't make much difference.

    By now, we can spot algae blooms via satellite, and predict what the oxygen depletion will be.

    But who is to blame and what the source is wont make any difference. If we are able to fix it, the system is so large that the cost to fix it is going to affect EVERYONE, no matter who you think you are going to send the bill to.

  27. " We already know that 38% comes from farms and 4% comes from septic tanks."

    how do you know that?

    where did those numbers come from?

    38% percent comes from ANY KIND of a farm no matter what kind?

    If the groundwater below a septic tank system has no elevated levels of nitrogen and phosphorous are you still going to make the owner do something – and what exactly would you require the owner to do ?

    Would you require them to put $10,000 worth of treatment plan for each drainfield?

    I don't think you know ANY of the above with any certainty at all and no one is going to go tell every farmer on every farm no matter what kind that they have to put 50K worth of remediation on their property no matter what….

  28. 38% agriculture, 19% municipal wastewater, 19% airborne. Plus or minus 10%. That's all you need to know. Even rocket scientists work with margins like that.

  29. where did you get that data?

    Isn't it just made up data?

    but even if it were true – does that mean that the same upgrades need to be done the same way for each land-use along the river?

    Same upgrade for all treatment plants no matter what?

  30. Larry, your own arguments are working against you here. There is no right to pollute, and we decide, not the polluter. If we decide to cut pollution 20% we just tell the farmer he can have 80 cows instead of 100.

    Done deal, because he has no right to pollute, and we decide what pollution is.

    He can appeal and offer an alternate plan, diapers for 20% of his cows. But the burden of proof is on him. And he has to proove the nitrogen in the diapers doesn't go in the river.

    Only we may be talking 50%, for everyone, not just farmers.

    Expect the price of steak and chicken to go up, and more imported beef.

  31. I expect the standards will apply blindly to all, yes. I expect conservatives who dislike government meddling will go berserk and people will be killed.

  32. The data is neither made up, nor precisely measured. It is a composite of measurements and models, because there is no other way to do it. You measure nitrogen on the uphill side of a farm and the downhill side. You do that a thousand times a.d make some inferences. Then you count the number and area of farms and the amount of runoff.

    The results are probably as accurate as measurements of global warming.

  33. no right to pollute does not mean the state can decide how much someone is polluting without evidence of them actually polluting and what they are polluting and how much.

    This is how the NPDES works.

    you get a pipe and you get a permit that specifies what you can discharge, in what concentrations and what quantity.

    You cannot assume that any cow on any land anywhere no matter what is "polluting".

    It may well be not the number of cows but their proximity to a water course – a swale or it might be a feedlot rather than 100 head running on 1000 acres and the creeks and swales are fenced already.

    The pollution has to be measureable and tied to a source.

    Without that evidence you'd just be assigning costs without any rhyme or reason – and without any assurance of actually reaching the required reduction for that water body.

    If you try to implement a policy such as this – you'll end up with people thrown out of office and the EPA – by law – prevented from further action on any level whatsoever.

    this is the wrong way to do it.

  34. "The data is neither made up"

    the data is made up if it is not actually measured.

    The problem with the models is they are so general that they only work for the entire river and not the actual sources and no locality and no farmer is going to spend thousands / millions of dollars without some evidence as to why – and some assurance that what they do will actually result is less pollution.

    We can do this right now with point source discharges by specifying the precise limits on the NPDES permit.

    Imagine trying to specify the permit criteria for individual permits – based on a river model.

    According to that model – you could just put as many discharge pipes as you wanted into the river as long as the model said it was okay.

    Then when the model said it was not okay – what would you do?

    Whose pipes would have to be removed or their allocation cut in half?

    how would you decide which pipes had to go and which had to be cut and which were still okay?

    that's the problem you have with non-point source runoff.

    Not all farms, for instance, are contributing the same amount and requiring all farms to take the same measures no matter what is dumb and expensive and will cause widespread opposition – people thrown out of office – and the whole plan put into the waste bin.

    If you wanted to sabotage the Bay Cleanup this is how you'd do it.

  35. The Potomac is still a festering cesspool. Just not as much. But it is a long, long way from clean.

  36. The Potomac and many other rivers in Va are significantly cleaner since they have upgraded the sewage treatment plants..

    The main problems that we have now are sediment, nitrogen, phosphorous, e-coli and mercury.

    Most of the rivers in Va that are on the 303D impaired rivers segments suffer from these issues and all of these problems emanate in part from non-point sources.

  37. It cannot be actually measured.

    I can take a sample from the bay and tell you how much nitrogen is in it, at that location and that time.

    Two minutes or two hours or two weeks later, I will get a different answer.

    And I can't tell you where it came from without spiking the suspected sources with tracers. Even then, it would be tough.

    But I do know something about all the sources and something about the transport methods, deposition, etc.

    I, personally spent years trying to learn something about atmospheric sulfuric acid. I sampled air and compared it with samples taken the same way inside cloud chambers where I could control the known inputs. I could tell you how much was acid, how much sulfate, and how much elemental or organic sulfur. I could tell you when it rains, how much will fall on the hood of your car. And I can tell you small drops are more acidic than big ones.

    But when it comes to the entire bay, all that is a giant extrapolation.

    But, once that sulfur goes up a smokestack in Ohio, I know it is coming down somewhere.

    At four corners there are huge power plants, and you can partially predict the weather in Colorado by studying the plumes.

    But there are not the kind of measurements you are suggesting, and there never will be, because The measurements would cost more than the cleanup. I don't believe we want people using gallons of high purity solvents to measure 3 parts per billion of PCB in a hundred tons of dirt. Not even if you think you can recycle 70% of the solvent with a huge refrigeration system using tons of fuel to run it.

  38. Let me know when you are willing to drink untreated Potomac.

    Significantly cleaner, yes.

    That is not saying much.

    There are springs on this farm which were once the domestic water supply, and which still empty into the Potomac.

    I'm not sure the springs themselves are ok, today, but I certainly would not go a mile downstream and drink. Let alone a hundred miles.

  39. well they DO measure it and it IS relatively consistent at the various monitoring stations so you're wrong again.

    and if what you said about variability was true then what is the model suppose to show and how would you validate it ?

  40. the standard Ray is swimmable, fishable. Even pristine sources are said to have risk of Guardia.

    again – the goal was never to restore the rivers to pristine.

    The TMDLs assumes pollution not pristine.

  41. At the ABC store you can buy triple distilled vodka.

    Trust me. You don't want to know why it is triple distilled.

  42. Not only can I assume any cow is polluting, I can tell you how much, on average. What is going to happen is that they will redefine what constitutes a pipe, so it includes non point sources. A farm will have X number of equivalent pipes.

    And let me tell you, if EPA claims you exceeded your discharge, good luck proving otherwise.

    A local firm turned themselves in for exceeding their discharge limit and reporting a false value due to an error in calculation. Cost them $50,000.

    For reporting an honest mistake, that made no material or noticeable difference in water quality.

  43. My farm is contributing zero since I have no animals. If they order me to cut in half, I will need to kill some wildlife. I will probably never have animals now, because that would cause an increase. I will have to buy animal rights from someone else who no longer wants them.

  44. Larry, there is stuff in the river they don't even measure. It is too expensive.

    And I'm not talking guardia.

    You probably could drink the water running off my farm for a long time without a problem.

    Five miles downstream? Not a chance.

  45. The monitoring stations have huge spikes during rain events. But the long term averages are consistent. That's only because the streams are already well mixed at the sampling stations.

    And the sampling they do is rudimentary. Nitrogen, phosphorous, dissolved oxygen, conductivity.

    It is like calling temperature and blood pressure a health checkup.

  46. I worked with a team that built a model to predict how a toxic plume would be distributed in an urban canyon environment.

    Then we went to a city and released a plume of tracers, with sampling stations all over the city.

    The measured results matched the predicted results.

    For that city on that day. We have no reason to think it would not work for any city where you have an accurate 3d map of the buildings.

    The model has been validated once. Is that enough?

  47. I don't know how many environmental analytical chemists there are around, or labs to support them, but one could pretty much make a career tracking the inputs and outputs from one or two good size farms.

    We are going to need a lot more chemists. And the lab I worked in was easily worth a half million in 1975 dollars, it is probably 5 million today.

  48. all we need is periodic stations along the river – automatically measuring and sending results via telemetry like they do right now.

    This cost is chump change compared to the dollars that will be required for cleanup.

    This kind of monitoring will help save money and to direct and prioritize the money that is spent to the areas with the most need.

    if you see a spike between two gages – then you do more instrumentation and field checking.

    this is common sense.

    excuses for not doing this is dumb and will lead to failure of the program.

  49. The very first thing that the new approach should do is to deploy a comprehensive network of automated sampling units across the watershed – much like the USGS has done with flow gages to predict flooding.

    it's common sense.

  50. "…automatically measuring and sending results via telemetry like they do right now…."

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

    Sorry, it doesn't happen that way.

    Some simple things can be done that way, but ordinarily you need frequent calibrations against known standards.

    Even though I used automated equipment that could analyze hundreds of samples, the sample have to be prepared,and they cannot be done in just any order.

    That was a long time ago, lord knows what they can do now. I'd take the advertizing literature with a huge grain of salt.

    Establishing many such stations in remote locations sounds like a no-go to me.

  51. they can do it – both ends

    but even on a manual basis it certainly is possible to take measurements at bridges manually and transport them.

    We do this every day at thousands of medical facilities for all manners of tests and we certainly can do something similar for these kind but I'm pretty darn sure the automation technology is here right now.

    USGS uses telemetry in remote places right now.

    They send signals via radio in a variety of ways to include cellular now.

    I can't believe you guy.

    You say you are a scientist but you are unaware of much modern technology.

    You did not even know that open road tolling is standard now and keep talking about toll booths.. and such.

    The technology is there right now guy.

    Even if it were not – you STILL have to do the comprehensive monitoring if you want to know how effective your cleanup is progressing and where to target the improvements.

    There is no way to no do that and still know what you're accomplishing.

  52. Biological oxygen demand still takes five days to measure. and its accuracy is still +/- 20%.

    I routinely had samples that took the machine an hour or more to analyze, after I calibrated the machine. You cannot rush the separation a chromatograph does, before it registers the sample.

    Yes, there are mechanical sniffers that can single out a particular explosive. Yes there are all kinds of new stuff, out there. Theroretically we couls catch every speeder on the highway: the technology is available.

    But what you are suggesting is still not doable. Not with todays technology and todays budgets.

    How would you measure the pollution from my farm? Monitor the two streams that leave it? What about all the other runoff that does not go via the streams? What about all the pollution that arrives from someplace else?

    Really, you are looking at a full time job, just to get a rough estimate of what is happening.

    If it was really as easy as you say, why hasn't it been done?

    The governor is talking about increasing the staff to help farmers reduce pollution from one person, to three persons.

    For how many farms?

    And these are not going to be professionals working on individual solutions: they are going to work out of a cannned list of things that are known to work. They will be applied more or less blindly with very little knowledge of how well they worked on a particular farm.

  53. "There is no way to no do that and still know what you're accomplishing."

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

    You will probably not know what you are accomplishing in an individual case, anymore than you would with social services or education, but you will see results change in the gross averages, eventually.

    The problem is if a little is good, more is better, and hence you will have creeping requirements. You will have less production, and more farms/businesses giving up.

    The ones that remain will be the largest and most technically and politically savvy.

  54. USGS uses telemetry in remote places right now.

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

    Not for biological oxygen demand.

  55. You simply cannot know what changes to specify and where until you know the areas that have the issues – and how bad.

    You cannot go around ordering thousands/millions of dollars of upgrades without showing that in that particular area there is a problem that justifies it – and that you can demonstrate that the improvements specified will yield a measureable improvement.

    Otherwise, you're going to have the government going around ordering expensive upgrades willy nilly without justification and without any assurance that even after the upgrades that the problem will be fixed.

    If you want Virginia to go to war with the EPA – this is the way to do it.

  56. Just watch.

    Look there is a lot of technology, and lots of new stuff. My experience says what you are demanding is highly impractical.

    And, I have been highly enforced for twenty years in order to prevent consequences no one has ever proven. EPA could be Virginia's next desegregation.

    I understand farmers are already organizing to Sue.

  57. " what you are demanding is highly impractical."

    every NPDES pipe right now is required to measure every constituent that is specified on their permit – that includes nitrogen and phosphorous for municipal waste water plants.

    You'll find these plants all up and down most major rivers in the Chesapeake Bay.

    There are a dozens on the Rappahannock and tributaries including what are called "package" plants which are essentially automated mini treatment plants.

    All that needs to be done is to have each of these plants add to their lab protocols – samples from the receiving body of water.

    The reason the farmers are going to sue is the very reason that I have been articulating here and that is they are not going to agree to pay thousands and millions of dollars without sufficient justification.

    And the municipal treatment plants are not either.

    They're all going to end up in court and before all is said and done – I predict that the localities and the farmers will provide their own UAAs and the judges will then require the EPA to justify their actions on a per site basis.

    Now the EPA will likely use a template for each kind of site but they'll be required to show the need – at that site – for the upgrade.

    But it will probably take years for this to work through the courts ….

    and like I said at the start …

    if you wanted to sabotage the clean up of the Bay – this is the way to do it… i.e. to proceed as if you don't have to justify your actions.

    If they had gone about this the right way from the start – they'd be on much firmer ground right now and much more able to defend their approach legally.

  58. Right. So how come I can't Sue for unproven consequences?

    I think you are wrong. What is going to happen to those colossal is the same as what happened to me, and for the same reasons – average consequences.

    Besides, measuring what comes from a pipe, based on a known process is easy. You don't have to look for pesticides coming from a rayon plant.

    A farm is not a pipe. And the inputs to a treatment plant is everything, not just rayon wastes.

    What you are suggesting cannot work. Even if it does work, the consequences amount to this: in order to really clean the bay, you basically have to repeal gravity, economics, and entropy.

    I don't see it happening.

  59. The lawsuits alone will take decades.

  60. …" the consequences amount to this: in order to really clean the bay, you basically have to repeal gravity, economics, and entropy"

    that's certainly not true.

    some folks with that same attitude said the Potomac could not get cleaned up and we could not keep toxics like Kepone and carbon disulfide in ground water at Front Royal – stopped and mitigated.

    The rivers in the Chesapeake Bay are much cleaner than they used to be but they suffer now from cumulative point and non-point source buildups of non-toxics like nitrogen and phosphorous (with the exception of air deposited mercury).

    We'll eventually get that done right also but our dysfunctional approach to implementation is causing delays.

    In the end – you have to do it right and that is going to require comprehensive basin-wide water quality sampling and monitoring – the SAME WAY – we NOW DO air quality monitoring and sampling for NOx and SOx and groundwater sampling and monitoring around landfills.

  61. Well – it turns out that at least one document that the EPA has generated recommends almost EXACTLY what I have been advocating:

    "Protocol for Developing
    Nutrient TMDLs"

    http://water.epa.gov/lawsregs/lawsguidance/cwa/tmdl/upload/2000_01_10_tmdl_nutrient_nutrient.pdf

    excerpt:

    " Source Assessment
    During source assessment, the sources of pollutant
    loading to the waterbody are identified and characterized
    by type, magnitude, and location.
    Linkage Between Water Quality Targets and
    Sources
    To develop a TMDL, a linkage must be defined between
    the selected indicator(s) or target(s) and the identified
    sources. This linkage establishes the cause-and-effect
    relationship between the pollutant of concern and the
    pollutant sources."

    Follow-up Monitoring and Evaluation

    TMDL submittals should include a monitoring plan to
    determine whether the TMDL has resulted in attaining
    water quality standards and to support any revisions to
    the TMDL that might be required. Follow-up
    monitoring is recommended for all TMDLs, given the
    uncertainties inherent in TMDL development (USEPA
    1991a; 1997a; 1999). The rigor of the monitoring plan
    should be based on the confidence in the TMDL
    analysis: a more rigorous monitoring plan should be
    included for TMDLs with greater uncertainty and where
    the environmental and economic consequences of the
    decisions are greatest.

    so now it appears that it is Virginia that is the problem.

    surprise. surprise.

  62. Give me a break. There is ONE air sampling station in Fauquier. The Potomac is far from clean.

    Better than it was, yes. Clean, no. And it depends on where in the Potomac.

    Yes, the approach has been haphazard, not to say nonexistent.

    I hope they succeed. However, I don't think anyone has the slightest clue how much this is going to cost. Realistically it is an infinite amount of money, because the lost opportunities will never come back.

    As it stands a good business makes 15%. If you increase clean up costs by 10%, you are basically dead. If you are a farmer or grocer, where your profit is 5% to start with, where does the cleanup come from?

    As for gravity, hundreds of thousands of tons of stuff is going downhill towards the bay every day. Some of it is bad stuff.

    How do you sort it out?

  63. Larry, Larry. That is not a protocol for how to determine a tmdl.

    It is barely a thought.

    Besides, its working from the wrong end. All you need to know is the minimum expected flow, and the maximum dose of pollution you can tolerate before too much damage occurs.

    That is your tmdl. Doesn't matter where it comes from.

    Next comes the question of how do you meet the standard most cheaply. That might mean that ALL the remediation falls on one activity.

    Next comes a decision as to how to share the cost. Anyone who is allowed to continue to use the watershed without cleanup cost ought to be willing to pay the Guy who cleaned up for them.

    This is what is wrong with the polluter pays idea: everyone pollutes, so everyone pays.

    But you start with the cheapest cleanup first.

  64. the UAA's bring economic analysis into the calculations…. and one outcome is that there is a point beyond which a particular cleanup action is uneconomic.

    The hard core bay cleanup folks never cared about that anyhow and were convinced that once a revenue stream was opened up from taxes that it could go on for decades and anyone involved would have a career in the Bay cleanup business.

    The Farmers and the Municipalities are going to bring some sanity to the process.

    Obviously what you want is the most bang for the buck – but easier said than done.

    One of the things that I have heard is that some folks think that wastewater treatment plants could have more restrictive standards put on them – to compensate for the more difficult task of dealing with non-point sources.

  65. I think if you take the time to read this and the associated links:

    http://water.epa.gov/scitech/datait/models/allocation/index.cfm

    you'll have to agree that they have a general protocol…approach… that targets the locations and links them to the mitigation and requires measuring to ensure that the mitigation is working.

    If they actually do that – from the get go – they're going to know what works and what does not and they will know where the worst of the problems are and to target them first – with the things they know that work.

    That's a far, far better approach that the "shotgun" that was advocated.

  66. A general protocol won't cut it. When I wrote those things it was a detailed set of instructions, same as you would use to launch a rocket. It took months to validate that if you followed the instructions you would get results that fell within an acceptable range of certainty.

    It would take ann army of people and a mountain of equipment, just to keep track of the acidity in the Chesapeake Bay watershed, in detail.

    And then you would have to aggrgate it to some kind of gross averages anyway.

    It is not going to happen, and we will either settle for gross average measurements, or spend the next century in court. Being a professional expert witness is likely to be a real growth industry.

  67. when the EPA says that you will tie the source to the specified mitigation and measure for effectiveness…. the detail protocols will reflect it.

    There are a lot of ways to accomplish that and many of them could be much more cost-effective than system-wide one-size-fits-all dictates.

    There is no feasible way to tie the source to the remediation and to verify effectiveness without measuring.

    Measuring is how you know if what you are doing is working or not – and how you find out what is cost-effective and what is not.

    Measuring might be expensive but it's far, far less expensive that not measuring.

  68. some folks think that wastewater treatment plants could have more restrictive standards put on them – to compensate for the more difficult task of dealing with non-point sources.

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

    I believe that, or something like is is exactly correct. Go after the easiest, cheapest fastest solutions and work your way up to the most expensive.

    But, the economic test is the real issues, not the chemical test. You can set any standard you like, with varying probabilities of success, and various ranges of costs. And the costs will affect various different constituencies.

    If you set the standard such that there is NEVER a newt with two tails, that's one standard. If you set the standard such that the economic value of using the Bay as a sewer is limited to a million dollars an hours, then that is a different standard.

    But, in the final analysis, this is ALWYAS going to come down to what do you think a human life is worth, and how come you value some more than others.

    It is the same problem you face in regulating Glock 16's.

  69. "Measuring might be expensive but it's far, far less expensive that not measuring."

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

    Not always.

    If I'm pumping the bilge, I need to know that the water is going out faster than it is coming in.

    But I don't need any more information than that, and additional information could easily cost more than it is worth. It is the same problem with tolls and user fees: ideally it works fine, but you have all those transaction costs.

    Now, I might have a trim problem, and alll the water is being pumped from one side or one end: then I need a little more info.

  70. totally wrong analogy guy.

    If you have a polluted body of water and you want to clean it up you need to know where it is coming from.

    I would equate your approach to the way we did business before the EPA required NPDES for pipes.

    No one really knew where the pipes were, how big they were and what was coming out of them.

    Your plan would be to do what?

    not find the pipes and not characterize what they are dumping?

    and do what instead?

  71. "States, territories, and authorized tribes are responsible for allocating loads among point and nonpoint sources identified under each Total Maximum Daily Load (TMDL). "

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

    This is the stupidest thing I ever heard of. Think about what that says: "Government is responsible for allocating who stays in business."

    +++++++++++++++++++++++++++++++++

    "Watershed modeling frameworks are tools that can be used to help evaluate the tradeoffs associated with different allocations. These framworks are capable of identifying cost minimizing allocations and comparing cost distributions across stakeholders under different allocation scenarios. "

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

    Nonsense. There is only one cost minimizing allocation: start with the most bang for the buck, low anging fruit, and work your way up.

    Cost distribution, is antoher matter, of course.

    But what this doesn't even address is the economic benefit derived per pollution unit allowed. For that, government would simply "allocate" all of the allowable load to the most valuable business, and let it operate up to the TMDL.

    Shut everyone else down.

    End of story.

  72. Ray – no business is shut down at all.

    It's the same approach used for NPDES which is to give a permit based on threshold limits.

    You do not have the right to pollute to start with.

    pollution is by permission and it's not according to what you think are the most valuable businesses.

    In fact, you DON'T want the government deciding which business are the "most valuable".

    but I'm glad you are actually reading here….

    at least you sound like you know more about it that you did before!

  73. Ray – the TMDLs are premised on the idea that there will be pollution – that's what TMDLs exactly are – Total Daily Maximum Loads.

    do you disagree with the CONCEPT of TMDLs or do you agree with the concept but not the implementation?

    which is it?

  74. well… now we know why you are not in charge of anything remotely connected to that problem.

    You're treating all the sources like they are equally damaging and all the waterbodies as if they are polluted to the same degree with the same kinds of pollution.

    you do not differentiate at all as to where the most significant problems are and of course how would you know since you don't want to know anyhow?

    In your bizarro world a heavily polluted section of river would not be cheap to clean up so you would pick the cheapest one to fix – the one with the least pollution – exactly backwards from the way it should be.

    you're a crazy guy Ray.

  75. You do not IMPLEMENT a TMDL.

    It is what it is. In this case Highest Possible Value = Production Value + External Cost + Government Cost.

    There is only one TMDL that maximzes total value over the entire system. And, it might be that such a TMDL simply values the river as a sewer.

    However, If you arbitrarily assign a TMDL, then there is only one use for the (allowed) pollution capacity that produces the most money and value. As soon as you figure that out, you could care less what all the other sources are, and making a big charade out of going out with an impossible measuring protocal is unneccessary and stupid.

    This is allocating your reconnaisance planes. Do you put them on the cloudy side of the island where the odds of seeing something is small but the payoff is high, or do you put them on the clear side whee the odds of seeing soemthing are high, but the likeliehood of it being there are low?

  76. now we know why you are not in charge of anything remotely connected to that problem.

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

    Precisely. If I was in charge it would have been fixed years ago. No one really wants this fixed.

    Look, how is the TMDL defined? It is not defined at the parts per billion of growth hormone bidegradation level. It is a high level gross definition to begin with. BOD, N, P, pH.

    Which industries give you the most money per unit of TMDL produced? Start at the top and work yur way down, until you have used up all the allowed TMDL units.

    TMDL is telling you you have a limited resource, make the best use of it.

    End of story.

    Just don't tell that story to anyone who is about to get killed by it.

    Now, how do you KNOW you have the best use? Auction it off. Cattle may not be the best income per TMDL produced today, but after you kill off enough cattle farms, the price may change.

  77. In your bizarro world a heavily polluted section of river would not be cheap to clean up so you would pick the cheapest one to fix – the one with the least pollution – exactly backwards from the way it should be.

    you're a crazy guy Ray.

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

    Genius is hard to fathom.

    How cheap it is to clean up depends on how much that section of the river produces. In this scenario cheap is determined by $ of net value produced per TMDL.

    Suppose you got one producer who is pretty cheap to clean up after, but you need a huge amount of government oversight to make it happen. Suddenly the net value for TMDL used is not so cheap.

  78. how about this guy.

    How about you tell me the basis of the EXISTING TMDLs BEFORE you tell me they are wrong.

    TMDLs do not "arbitrarily" decide as you say…

    but I'm going to ask you to find out and tell me what the basis is because they DO allow pollution but the numbers allowed are not arbitrary.

  79. Ray – no business is shut down at all.

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

    Of course they are, we do it all the time.

    You got one business that produces $1000 per TMDL unit used and another that produces $1 per TMDL unit used.

    Given that I have a fixed amount of TMDL to issue, Every time I let one of those second businesses continue, they use a TMDL that would have produced more money elsewhwere. It costs me $999 per TMDL used, by the second business.

    The choice is obvious, and I have to shut them down.

    But now you argue, what if it is cheaper to clean up after the small business: ten cents per TMDL vs $500 per TMDL cleaned up for the big one. In that case, for a dollar of additional cleanup, I get $10 in additional production from the small business vs only $2 in addtional production from the big one.

    Nice try, but it doesn't work that way, for several reasons.

  80. The important thing to realize, is that it isn't about cleanup, its about money. The TMDL just tells you how much money you can make.

  81. no businesses that I know of have been shut down for violating TMDLs.

    In order to do that – someone would have to prove that they put more into the river than they were allowed to or that they could not farm unless they got a permit to farm.

    Tell me where we do this.

    Any business is allowed to operate if they meet the criteria for discharges even now.

    By your logic Avisco and Allied Chemical were "run out of business", right?

    you've slid back buy.

    No one has a right to pollute.

    It's by permission only and you can't get get a permit by proving that the cost of your pollution is less than your profits.

    We've been over this before.

    do you want to go back through it again?

    no none has the inherent right to pollute and no one has the right to pollute even if they think their profits are worth more than the harm done by their pollution.

  82. How about you tell me the basis of the EXISTING TMDLs BEFORE you tell me they are wrong.

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

    What do you mean, basis? Chemical basis, or monetary basis?

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

    Look suppose I build a brick wall and it takes me ten hours. I hire a guy to help and we do it in four hours, eight man-hours.

    But if I hire nine guys, I can't do it in an hour, and probably when I get done I've now got 12 man-hours in it.

    You have three variables, and you have to make one fixed to solve for the other two, unless you have a lot of cases, and you can do a multivariate analysis.

    If you decide that the goal is to maximize the GDP of the system,then you must recognize that this might mean an unlimited TMDL. But, for any fixed value of TMDL there will be a maximum value for the sum of production, plus cleanup plus oversight.

    It does not matter WHAT the basis of the TMDL is. As soon as it exsists, it represents another form of resource, same as labor, power, materials or anything else.

    You have a machine shop, and it has one punch press and one lathe and three workers with known skills, there is only one set of products you can produce that will make you the most money.

    Suddenly you have a TMDL that says you may only dispose of 500 lbs of punchings every day. It makes no difference to you whatsoever what the basis for that TMDL. The result is that your most profitable mix of products changes.

    Suppose now the TMDL is more specific: it is not just 500 lbs of punchings, the totol NUMBER of punchings may not exceed 50,000, and not more than 5000 may exceed one inch in diameter.
    (Not more than 50,000 total TMDL units of which not more than 5000 may be BOD units, and not more that 20,000 may be N units).

    All you have done is subdivide the TMDL into multiple resources which have to be allocated, and you will soon find some other mix of products taht is the max profit you can make given those constraints.

    Not only that, but now you may discover that you run out of allowable one inch punches before you run out of allowable total weight. Provided the allotment is transferrable, you could sell your remaining weight allowance to someone else, so the production capacity would not be lost. Or you buy or rent some othar machine so you can use the allotment.

    But the point is, it makes no difference whatsoever how the allotment is made, described, or justified: the problem of (and solution for) maximizing the dollar value it allows is EXACTLY the same in every case.

    There is no right or wrong on TMDLs, but there is always an associated price. You can set the TMDLs without regard to price. (Our TMDL is no two tailed louseworts), but as soon as you do that, a price will happen.

  83. How about you tell me the basis of the EXISTING TMDLs BEFORE you tell me they are wrong.

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

    What do you mean, basis? Chemical basis, or monetary basis?

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

    Look suppose I build a brick wall and it takes me ten hours. I hire a guy to help and we do it in four hours, eight man-hours.

    But if I hire nine guys, I can't do it in an hour, and probably when I get done I've now got 12 man-hours in it.

    You have three variables, and you have to make one fixed to solve for the other two, unless you have a lot of cases, and you can do a multivariate analysis.

    If you decide that the goal is to maximize the GDP of the system,then you must recognize that this might mean an unlimited TMDL. But, for any fixed value of TMDL there will be a maximum value for the sum of production, plus cleanup plus oversight.

    It does not matter WHAT the basis of the TMDL is. As soon as it exsists, it represents another form of resource, same as labor, power, materials or anything else.

    You have a machine shop, and it has one punch press and one lathe and three workers with known skills, there is only one set of products you can produce that will make you the most money.

    Suddenly you have a TMDL that says you may only dispose of 500 lbs of punchings every day. It makes no difference to you whatsoever what the basis for that TMDL. The result is that your most profitable mix of products changes.

    Suppose now the TMDL is more specific: it is not just 500 lbs of punchings, the totol NUMBER of punchings may not exceed 50,000, and not more than 5000 may exceed one inch in diameter.
    (Not more than 50,000 total TMDL units of which not more than 5000 may be BOD units, and not more that 20,000 may be N units).

    All you have done is subdivide the TMDL into multiple resources which have to be allocated, and you will soon find some other mix of products taht is the max profit you can make given those constraints.

    Not only that, but now you may discover that you run out of allowable one inch punches before you run out of allowable total weight. Provided the allotment is transferrable, you could sell your remaining weight allowance to someone else, so the production capacity would not be lost. Or you buy or rent some othar machine so you can use the allotment.

    But the point is, it makes no difference whatsoever how the allotment is made, described, or justified: the problem of (and solution for) maximizing the dollar value it allows is EXACTLY the same in every case.

    There is no right or wrong on TMDLs, but there is always an associated price. You can set the TMDLs without regard to price. (Our TMDL is no two tailed louseworts), but as soon as you do that, a price will happen.

  84. Ray – aren't you the one that advocates for fishery "shares" and auctioning for "rights"?

    Do you think that TMDL allocates specifically to businesses?

    Do you think – if they do – just like with NPDES – that as long as you meet the requirements of the permit that you can produce as much as you want and if you come up with a better process that produces more widgets with less pollution that you'll best your competitors who can't figure out how to pollute less?

    Do you think that someone could sell their excess TMDL "credits"?

  85. Look, there are a max number of pollution units you can put down a stream, same as there are a max number of vehicles you can push down a street.

    If you send too few, or try to send too many, then costs go up, whether it is vehicles or pollution units.

    Pollution units count different if they are N, P, BOD or Kepone, just as vehicles count different if they are bicycles, autos and tractor trucks.

    But once you specify (allocate) the allowable mix, you have determined the cost per vehicle and the value of that street. If you have decided you can only have 500 trucks, are you now gong to ALLOCATE how many trucks for each company? Or do you just let the comapny willing to pay the most use all the slots?

  86. isn't that the same way that fisheries and acid rain are currently handled – and you have supported?

    If you have a finite resources, you can auction off the allocations?

    fisheries, acid rain, congestion tolling?

  87. Do you think that TMDL allocates specifically to businesses?

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

    That is what it sounds like from the source you quoted.

    "States, territories, and authorized tribes are responsible for allocating loads among point and nonpoint sources identified under each Total Maximum Daily Load (TMDL). "

    Sounds to me like they are going to tell each source what their allocation is. Furthermore it sounds like they have a plan for the "best" allocation, based on some model.

    "Watershed modeling frameworks are tools that can be used to help evaluate the tradeoffs associated with different allocations. These framworks are capable of identifying cost minimizing allocations and comparing cost distributions across stakeholders under different allocation scenarios. "

    I'm sorry, but
    "comparing cost distributions across stakeholders" means telling them how much profit they can have, including NONE if it provides a better distribution across stakeholders.

    Yes, I think you decide (on some basis) what the TMDL load and TMDL mix is. Then you sell the right to use shares of the allowable TMDL load.

    As soon as you do that, you have created a right to pollute, or at least a vested interest. If Joe's autobody has paid you for 500 TMDls figuring it will allow him a profit of $500,000 per year, then you have a deal.

    If you later reduce it to 200TMDLs then you need to give him the money back that he paid you.

    AND you ought to pay him for his losses in investing in a $500k plant which can now produce only $200k.

    You ought to leave it up to the Joes of the world to figure how much they can afford to pay. And wahtever the sum of the result is, is the value of the TMDLs.

    Lets suppose that the sum value of money paid in for TMDLs is $750 million. And lets suppose that the BASIS for setting the TMDLs was that the reduction in pollution would save 100 lives a year due to reduced environmental risk.

    That woule work out to $7.5 million per life, which is just what EPA uses.

    If the Joes of the world are willing to pay less, then the cost per life is out of whack with regard to the TMDL level chosen.

  88. Do you think that TMDL allocates specifically to businesses?

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

    That is what it sounds like from the source you quoted.

    "States, territories, and authorized tribes are responsible for allocating loads among point and nonpoint sources identified under each Total Maximum Daily Load (TMDL). "

    Sounds to me like they are going to tell each source what their allocation is. Furthermore it sounds like they have a plan for the "best" allocation, based on some model.

    "Watershed modeling frameworks are tools that can be used to help evaluate the tradeoffs associated with different allocations. These framworks are capable of identifying cost minimizing allocations and comparing cost distributions across stakeholders under different allocation scenarios. "

    I'm sorry, but
    "comparing cost distributions across stakeholders" means telling them how much profit they can have, including NONE if it provides a better distribution across stakeholders.

    Yes, I think you decide (on some basis) what the TMDL load and TMDL mix is. Then you sell the right to use shares of the allowable TMDL load.

    As soon as you do that, you have created a right to pollute, or at least a vested interest. If Joe's autobody has paid you for 500 TMDls figuring it will allow him a profit of $500,000 per year, then you have a deal.

    If you later reduce it to 200TMDLs then you need to give him the money back that he paid you.

    AND you ought to pay him for his losses in investing in a $500k plant which can now produce only $200k.

    You ought to leave it up to the Joes of the world to figure how much they can afford to pay. And wahtever the sum of the result is, is the value of the TMDLs.

    Lets suppose that the sum value of money paid in for TMDLs is $750 million. And lets suppose that the BASIS for setting the TMDLs was that the reduction in pollution would save 100 lives a year due to reduced environmental risk.

    That woule work out to $7.5 million per life, which is just what EPA uses.

    If the Joes of the world are willing to pay less, then the cost per life is out of whack with regard to the TMDL level chosen. They might be willing to pay less if the TMDL level is set EITHER too high or too low.

  89. " If the Joes of the world are willing to pay less, then the cost per life is out of whack with regard to the TMDL level chosen."

    who says?

    you?

    you keep forgetting guy – that it's not at all about what a life is worth ….much less who gets to decide it.

    we do not set pollution policy based on what some might value a life to be.

    If no one died but 50% of women and kids suffered a 10 point loss of IQ – how would you figure that cost?

    If the crabs and oysters disappeared from the Bay what is that worth?

    If the bay ended up devoid of animal and plant life what is that worth?

  90. If you set the TMDls so that the value per life saed is $7.5 million everyehwere, then one liefe is valued the same as another. Otherwise you are claiming that a life saved in one watershed is worth more or less than a life saved in antother watershed.

    But, if you set the TMDls differently, to equalize the value of a life saved, you will discover that the value of one watershed as a sewer is higher than another.

  91. " If you set the TMDls so that the value per life saed is $7.5 million everyehwere,"

    so no matter the stream or it's current condition or flow – everyone gets an equal pollution share?

    ha ha ha ha … you're a stitch

    we're at 90 comments.

    I'm done at 100.

  92. you keep forgetting guy – that it's not at all about what a life is worth ….much less who gets to decide it.

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

    No, you eep forgetting, that as soon as you set a TMDL or any other standard, the cost of implementing that standard implies a value of human life.

    We spend X amount on seat belts and air bags and save Y lives. X dollars per life. It has nothing to do with what I think.

    Would you suggest one seat belt standard in one watershed and a different one in another?

    Lets assume that seat belts and air bags save lives at a cost of $7.5 million per life.

    How can you justify a TMDL that saves lives at either $2 million per life OR $20 million per life? In one case you would be better off letting the stream be dirtier and sending the money on seat belts, and in the other case you would be better off spending less on seatbelts and getting a cleaner stream.

    My opinion has nothing to do with it.

  93. If the crabs and oysters disappeared from the Bay what is that worth?

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

    Look, we know that crabs and oysters are disappearing. We know how much money has been made in the past hundred years making the crabs and oysters disappear.

    If you make all that money disappear to get the crabs and oysters back, you just set a value on crabs and oysters. If you make half the money disappear and get half the crabs back, then it is the same price per crab.

    But the function is almost certainly nonlinear, so there is one amount of money that you can make in the Bay watershed that minimizes the cost of crabs.

    I don't make this stuff up. dollars spent on seatbelts divided by lives saved = dollars per life.

    Income foregone by industry in the bay watershed divided by increase in crabs = price per crab saved. Add to that the cost of catching and marketing the crabs and you have the cost per crab sold, which is one of the components of industry in the bay watershed. But the cost borne by industry to protect those crabs does not show up inthe price of the crab. It is an external cost. So the Total cost of crabs is

    TC = production cost + external cost + government cost.

  94. " no, you eep forgetting, that as soon as you set a TMDL or any other standard, the cost of implementing that standard implies a value of human life."

    you are so FULL OF IT.

    Tell me why School Buses and Commuter buses and trains and subways do not have seat belts…..

    tell me the difference between one life and 10,000 people with serious illnesses that destroy their ability to live a normal life.

    Calculate for me what one point of IQ is worth in a child or someone who went swimming and now has Hepatitis C?

    do you have any clue what the definition of fishable and swimmable is?

  95. " Designated Uses
    The water quality standards regulation requires that States and authorized Indian Tribes specify appropriate water uses to be achieved and protected. Appropriate uses are identified by taking into consideration the use and value of the water body for public water supply, for protection of fish, shellfish, and wildlife, and for recreational, agricultural, industrial, and navigational purposes. In designating uses for a water body, States and Tribes examine the suitability of a water body for the uses based on the physical, chemical, and biological characteristics of the water body, its geographical setting and scenic qualities, and economic considerations. Each water body does not necessarily require a unique set of uses. Instead, the characteristics necessary to support a use can be identified so that water bodies having those characteristics can be grouped together as supporting particular uses.

    Where water quality standards specify designated uses less than those which are presently being attained, the State or Tribe is required to revise its standards to reflect the uses actually being attained.

    A use attainability analysis must be conducted for any water body with designated uses that do not include the "fishable/swimmable" goal uses identified in the section 101(a)(2) of the Act. Such water bodies must be reexamined every three years to determine if new information has become available that would warrant a revision of the standard. If new information indicates that "fishable/swimmable" uses can be attained, such uses must be designated."

    http://www.epa.gov/waterscience/standards/about/uses.htm

    Use Attainability Analyses (UAAs)

    http://water.epa.gov/scitech/swguidance/waterquality/standards/uses/uaa/uaa_index.cfm

    The most significant misperception about designated uses and UAAs is that UAAs need only address the current condition of a waterbody: that a designated use may be removed simply by documenting that protective criteria are exceeded. However, it is the prospective analysis of future attainability of designated uses that provides the demonstration necessary to support a use change. A related misconception is that UAAs are only a means to remove a designated use. In fact, UAAs have supported both removing uses and adding uses. The program experience and future direction reflects a growing practice of "sub-categorizing" or "refining" designated uses; that is, making them more specific and precise as opposed to removing them.

  96. so no matter the stream or it's current condition or flow – everyone gets an equal pollution share?

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

    Good question.

    I would say that one life is worth the same as another, whatever that value is. I would say that we cheat some people by spending more to protect them than others. If we are spending too much to protect them we should spend less and they will be subjected to more pollution.

    Looked at the other way, we claim we all own the environment. No one has a right to pollute our property, and so there is no right to pollute.

    On the other hand, part of the value of the environment is its ability to act as a sewer. If we all own the environment we all own a share of its ability to handle waste.

    People who don't feel as if they are being poisoned might be willing to sell their share, and people who do, won't. But everyone needs a job, so the polluters will have to buy their shares, somehow.

    At the end of a year, you will have a certain amount of industrial production, which will support some people and also cause pollution that kills some people.

    In this case, the value of pollution credits sold by individuals (instead of allocated by government) minus the value of production (including the value of jobs supported) – minus the cost of government oversite and regulation, that sum, divided by the number of envronmental related deaths would be the amount we would have to give up to save one statistical life.

    Under such a system there would be no argument about what a life is worth, because we would have voted with our wallets, and that is what we sold those lives for.

    Now, we can put all kinds of intermediaries in the system, like EPA and Sierra Club and the National Chamber of commerce, so we can pretend this isn't what is happening, but after yu get through alll the negotiation and litigation, that is what it actually is.

    We can put more EMT crews on the stretts and save more lives, but each one we put out there will save fewer lives than the last one, and eventually we will say, no more. That is the price we put on human life, or one of them.

    Next we put up a TMDL that is supposed to save lives (and crabs, which support lives). Is that TMDL going to cost us more or less per life than the next EMT crew?

  97. "Appropriate uses are identified by taking into consideration the use and value of the water body for public water supply, for protection of fish, shellfish, and wildlife, and for recreational, agricultural, industrial, and navigational purposes."

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

    Which is what I said, you put a price on the use of it.

    Over time, that price and the cost of protecting it may change.

    As a result, people who are excluded from using it may be willing to pay more than the people who are using it.

    That is why you need a market to discover the values, and not have them "allocated".

  98. Use attainability analysis.

    What a crock of crap.

    Either you use it for something or you dont. If you use it for something that has a value, and the cost of that use includes the cost of being excluded from other uses ("non – attainment").

    Or you use it for the other use,in which case you are excluded from this use, and it becomes and external cost.

    TC1 = Value of use 1 – loss of use 2 + government cost.

    TC2 = Value of use 2 – loss of use 1 + government costs.

    One total cost will be lower than the other one.

    Barf like use attainability analysis is why I got out of the business. It is written by a committee devoid of intellect or reason, and then it is litigated by lawyers with even less.

    It is not that hard. You will set a standard of cleanliness which implies an allowance for dirtieness, which in turn means certain things are allowed and certain things are excluded. That define the cash flow the resource can support, and sets the value of the resource.

  99. Use attainability analysis.

    What a crock of crap.

    Either you use it for something or you dont. If you use it for something that has a value, and the cost of that use includes the cost of being excluded from other uses ("non – attainment").

    Or you use it for the other use,in which case you are excluded from this use, and it becomes and external cost.

    TC1 = Value of use 1 – loss of use 2 + government cost.

    TC2 = Value of use 2 – loss of use 1 + government costs.

    One total cost will be lower than the other one.

    Barf like use attainability analysis is why I got out of the business. It is written by a committee devoid of intellect or reason, and then it is litigated by lawyers with even less.

    It is not that hard. You will set a standard of cleanliness which implies an allowance for dirtieness, which in turn means certain things are allowed and certain things are excluded. That define the cash flow the resource can support, and sets the value of the resource.

  100. Groveton Avatar

    I was very imprerssed with myself when I saw that this article generated 100 comments.

    Then I realized that the last 85 comments of the 100 were a back and forth between LarryG and Hydra.

    85 consecutive comments.

    Well boys, I am happy that the two of you have found something to talk about!

    I am on the west coast today (SF). Snow kept me out of Boston and is making the trip back to VA a challenge.

    However, the next installment is underway.

    All of the questions and comments between the Band of Bay Brothers – Hydra and LarryG – are valuable.

    Keep 'em coming.

  101. Gooze Views Avatar
    Gooze Views

    Groveton,
    I asked Bacon if we could have a rewards program, i.e. if you get 100 or so comments on your blog post, he has to pay for your tropical vacation.
    Bacon thought it was a great idea but then said: "comments from Ray or Larry don't count."

    Peter Galuszka

  102. Hey LISTEN! If you Yahoos would do your share of the commenting we wouldn't need to be talking about a "rewards" program or Larry or Ray….

    Ya'll ought to thank us – for the entertainment, eh?

    BR's own version of Punch & Judy!

    At any rate I'm looking forward to Groveton's further posts on this subject as I'm quite sure he will explore some aspects that have not been so far.

  103. Andrea Epps Avatar
    Andrea Epps

    OK, I'm all in for the tropical vacation!
    These are my local regs for the reservoir i live on.

    Watershed assessment and stream protection program:

    http://www.chesterfield.gov/content2.aspx?id=2858

    Water Quality Reports:

    http://www.chesterfield.gov/content2.aspx?id=2852

    Light bedside reading:)
    When are we leaving?

  104. thanks Andrea:

    " Comprehensive assessments of sub-watersheds to identify and evaluate the sources of water quality degradation

    Establishment of watershed management strategies based on the detailed watershed assessments"

    then:

    " Nutrient concentrations varied among sites and within watersheds for 2007. The
    median total ammonia nitrogen for 2007 was calculated at 0.06 mg/L as N. Generally
    total ammonia concentrations were greater throughout the county as compared to the
    previous year. Likewise, overall nitrate+nitrite nitrogen concentrations were lower than
    observed the previous year. The median nitrate+nitrite nitrogen concentration for all
    reaches in 2007 was 0.03 mg/L as N. For the third year in a row, nitrate+nitrite
    concentrations were the greatest at No-Name Creek (JR-01; 1.26 mg/L as N)."

    so a quiz…

    are these nitrogen levels low, med or high?

    Would these streams be subject to the Chesapeake Bay TMDLs and if they are – are the nitrogen levels "actionable"?

    Let's see if Groveton knows.

    I know that Ray does not.

  105. Andrea Epps Avatar
    Andrea Epps

    you're welcome.
    That website has a ton of info and data that has been collected over the years. If you find the details on the Swift Creek Reservoir, there's even more data.
    That water body has been the source of much debate over the years, similar to the current TMDL debate.
    🙂

  106. Andrea – from time to time, I read about the Swift Creek issue and the concerns – not unlike the issues a few years back with the Occoquan Reservoir in NoVa.

    One of the interesting things to me about the TMDL / nutrient issue is that reservoirs are ideal venues for determining nutrient inputs to a waterbody since the impoundment tends to minimize the daily fluctuations and calibration issues that you have with free-flowing water bodies.

    It should be much easier to look at the smaller watershed of these impoundments as more of a closed system that should give you a fairly good fix on the difference between background levels of nutrients and the added inputs.

    I see these reservoirs as becoming key laboratories for calibration of TMDLs…

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