Water Quality Task Force Meeting
Meeting Summary
Participants
|
Gregg Good |
|
|
Matt Short |
|
|
Roy Smogor |
|
|
John Olson |
|
|
Tom Wilton |
|
|
Will Bouchard |
|
|
Shannon Lotthammer |
Minnesota PCA |
|
Mohsen Dkhili |
Missouri DNR |
|
Jim Baumann |
Wisconsin DNR |
|
John Sullivan |
Wisconsin DNR |
|
Bill Franz |
US EPA, Region 5 |
|
Ted Angradi* |
US EPA, ORD |
|
Brent Bellinger* |
US EPA, ORD |
|
David Bolgrien* |
US EPA, ORD |
|
Mark Pearson* |
|
|
Karen Hagerty |
USACE |
|
Mike Coffey |
|
|
Bob Buchmiller |
USGS |
|
Chris Yoder |
Midwest Biodiversity
Institute |
|
Peg Donnelly |
UMRBA/US EPA, Region 5 |
|
Dave Hokanson |
UMRBA |
|
Nat Kale |
UMRBA |
|
Barb
Naramore |
UMRBA |
*Joined the meeting by phone, first day
only.
Call to Order and Introductions
The meeting of the UMRBA
Water Quality Task Force (WQTF) was called to order at
Corrections to Previous Meeting Summary
Nutrients
Discussion
Recap and Reaction to Nutrient Project
Work Session
Nat Kale reviewed discussions
from the previous day’s nutrient project work session, grouping the input
received into three main categories: 1)
suggested changes to the way certain topics are addressed, requiring some
re-writing but no new information collection; 2) suggested expansion of
discussions within the existing scope of the project, which may require some
new information collection and some new writing;, and 3) suggested additions of
entirely new sections/information to the report. He said that one purpose of the discussion
today is for the WQTF to provide input on how to respond to these suggestions –
i.e., deciding which elements to incorporate and which to set aside for future
work.
Roy Smogor asked if anyone
was aware of research regarding the effects of nutrients on heterotrophs. Tom Wilton said there has been some research
in this area, as Joanne Burkholder had mentioned the preceding day, and that
dissolved oxygen minima may have a relationship to both heterotrophs and
autotrophs. Will Bouchard said MPCA is
investigating such relationships. John
Sullivan said his understanding is that dissolved oxygen drops are largely
resulting from algal activity. Bouchard
said this understanding is correct.
Sullivan said the nutrient-bacteria relationship did then not seem to be
a main theme for the report.
Hokanson said his
understanding of the WQTF’s input today is that the nutrient-bacteria issue
should be mentioned, likely in the impacts section, but there would not be
associated findings or recommendations.
Shannon Lotthammer agreed this seemed to be an appropriate
approach. Olson suggested that this, and
other topics such as drinking water supply issues, could perhaps be addressed
in an emerging issues section. Franz
agreed, saying that this section could point to areas where further work is
needed. Good also commented that he
favored an emerging issues section.
Kale identified nitrate
impacts as an area where greater time and effort should be dedicated in
revising the report. Lotthammer agreed
with this emphasis, saying that the preceding day’s discussion really brought
this out as an area to be addressed in greater detail. Baumann said that nitrate toxicity will
become a bigger issue once
Hokanson
and Kale asked what the WQTF would like to see done in the report with other parameters
that had been suggested for examination – pH, silica, biological oxygen demand,
and total organic carbon.
Sullivan suggested that
dissolved oxygen and biological oxygen demand could be discussed together in
one section, although he recommended that this not be an extensive
section.
Sullivan said an
oxygen-related section could perhaps also address the need for continuous
monitoring. Kale agreed a reference to
continuous monitoring could be included.
Good noted that continuous monitoring is part of the new National Great
Rivers Research and Education Center (NGRREC) facility at
Kale asked whether
statistical analysis of nutrient and related LTRMP data is something that the
WQTF would like to see included in the report.
Roy Smogor said new statistical analyses probably wouldn’t provide more
information than is already known and are unlikely to really capture the complexity
of interaction. Sullivan said he has
done a lot of correlation analysis with LTRMP data and has observed some
correlations, particularly in regard to light penetration. But he observed that response can be quite
variable.
Good asked whether these
types of relationships are important to understand from a standards development
viewpoint. Baumann said many of the
relationships that could be examined via statistical analysis are already
documented in the literature and in
Hokanson said that, given the
amount of work requested on the nutrient report, and the amount of time that
Kale has already put into this project task (as opposed to the biological
assessment guidance), it will be necessary to rebalance Kale’s time allocation,
which was originally to be split evenly between the two project tasks. WQTF members indicated that this type of rebalancing
should not be problematic, but requested that UMRBA send an email documenting
the reallocation.
Updates on States’ Nutrient-Related
Efforts
Good gave a brief update on
Baumann said Wisconsin
Smogor said US EPA Region 5
has asked for nutrient and biological data from
Lotthammer said the technical
support documents for
Good said he had heard there
may be a workshop to discuss
Dkhili reported that
Wilton said that, beyond its
lakes criteria, Iowa is working on issues related to stream criteria via a
technical committee, but noted that even basic issues such how to characterize
data have been a challenge. He said the
intent in addressing criteria for flowing waters is to start with wadeable
streams and then work on larger rivers, though it is not known whether this
will include the UMR.
Sullivan asked if and how the
states are dealing with wetlands and nutrients, noting that UMR backwaters may
be a closer fit for wetland-focused standards than lake or river
standards. Baumann said wetland-focused
nutrient standards are on
Outcomes of November 2010 UMRBA
Board/WQEC Meetings
Hokanson reviewed the
outcomes of the
Hokanson highlighted requests
for input made by U.S. EPA Region 7 Water, Wetlands and Pesticides Division
Director Art Spratlin during these meetings.
He said Spratlin had sought input from the WQEC in two areas: 1) water quality strategies and priorities
for the Mississippi River which would be shared with Region 7 Administrator
Brooks for his use in conversations with other Regional Administrators and U.S.
EPA Headquarters, and 2) water quality-related science needs to be shared by
Region 7 with U.S. EPA’s Office of Research and Development (ORD), in the
context of Region 7’s role as liaison to ORD.
Hokanson explained that the
WQEC, in consultation with UMRBA’s Board, would be responding to Spratlin’s
first request in the form of a letter to Regional Administrator Brooks. He said this letter is currently in draft and
is being reviewed by both the WQEC and the Board. Hokanson noted that themes in the draft
letter include:
§
Support for the
Regional Administrators’ interest in raising the profile of the
§
The important
role of the Regional Administrators in sustaining a vision for the
§
The need for
enhanced, Clean Water Act-focused, monitoring of the UMR.
§
The states’
interest in developing a shared, UMR-focused approach to reducing nutrient
impacts.
Hokanson said UMRBA is
awaiting additional information from Region 7 before crafting its response to
Spratlin’s request regarding science needs.
Hokanson did note, however, that needs identified by the WQEC included
extrapolation of LTRMP data, support for the continued implementation of
biological assessment approaches, and nutrient-related research. Dkhili commented that extrapolation of data
was potentially a broader issue than just LTRMP data, as U.S. EPA has sought to
extend site-specific impairments, such as the localized lead and zinc
impairment at Herculaneum, to entire river reaches.
Hokanson reported that the
WQEC discussed potential topics for cross-programmatic workshops under the
604(b) agreement and expressed a strong preference for focusing on
nutrients. Further, the WQEC had
suggested holding two similar workshops in different locations to facilitate
attendance.
Finally, Hokanson mentioned
that the WQEC had also used part of its meeting time for a discussion with
members of the Mississippi River Collaborative, a group of NGOs funded by the
McKnight Foundation and focused on
Planning for Cross-Programmatic
Workshops
Hokanson requested input from
the WQTF regarding the content of the cross-programmatic workshops, within the
WQEC’s general direction for two similar workshops focused on nutrient
issues. He reminded the WQTF that, since
these workshops would be one time events, they may need to be structured
differently than other recent efforts, which have provided more than one
opportunity to bring participants together.
Franz and Mike Coffey
suggested that the Mississippi River Health Watersheds Initiative (MRBI) could
be a topic for the workshops. Good and
Naramore suggested that the approach of
Good asked Coffey to comment
on why nutrients are important from the Fish and Wildlife Service’s
perspective. Coffey explained that
nutrient interactions with biota are key, as well as the implications these
interactions have for sound resource management (e.g., effects of river
projects to restore connectivity).
Good and Franz said water
suppliers’ issues could perhaps be part of the workshop agenda.
Smogor suggested that the
workshops could focus on nutrient standards and the pros and cons of nutrient
criteria specifically. Good said an
exclusive focus on standards would be too narrow. Lotthammer suggested that an update regarding
the Hypoxia Task Force’s work should be included as a way of fostering
connections with that group’s efforts.
Franz said he could likely find someone to speak about the Gulf Hypoxia
effort and also suggested that Dale Robertson provide an update on SPARROW
modeling efforts.
Smogor asked whether the
workshops would focus more on science issues or on the sharing of
perspectives. Good replied that he
envisioned them more in the realm of sharing perspectives. Donnelly said part of the WQEC’s thinking in
having two workshops was to facilitate engaging agriculture interests in the
discussion. Dkhili said that, in terms
of encouraging participation,
Smogor commented that, at
least in part, the workshops could help educate stakeholders about how
nutrients fit into CWA programs. Matt
Short said similar efforts by Illinois EPA to engage stakeholders on nutrient
issues have been helpful. Coffey said
another workshop objective could be to explain the importance of Gulf Hypoxia,
acknowledging that this is not necessarily a driving issue from a local
perspective.
Naramore
said it is important to decide if the workshops will have primarily a standards
focus or will be more broad-based. Smogor
said a focus on standards assumes that standards for the river are
forthcoming. Short said since standards
are often driven by interior waters, it is important to have specific
consideration of large river and interstate issues. Baumann said that he is less interested in
standards than in how to move forward in non-point source pollution
control. He said much could be learned
by hearing how people are successfully addressing non-point source control. He said potential topic areas for the workshops
could include standards, monitoring, and non-point source control
implementation. Lotthammer said having
the monitoring and implementation discussions, along with a standards
discussion, is a good idea. Good said
statewide nutrient reduction plans could also be part of the discussion.
Franz suggested perhaps
removing standards from discussion, as it is a lightning rod, and focusing
instead on applications for non-point source control. Good disagreed, saying that the lightning rod
issues such as standards are exactly the issues that bring people to the
table. Good continued by asking Baumann
if he thought a discussion of cost sharing would be beneficial. Baumann agreed that this would be helpful and
would perhaps be a chance to clear up misconceptions about cost sharing in
In summary, the following
topic areas/tracks were suggested by the WQTF for the nutrient-focused
workshops:
Good suggest that UMRBA staff
draft up a proposal for workshop content and structure, and then circulate this
back to the WQTF. All agreed with this
suggestion.
Aquatic Life Designated Uses Project
Presentation of Final Draft Project
Report
Donnelly presented a summary
of the draft aquatic life designated uses (ALDU) report, including a summary of
the data and data analyses incorporated into the report. Regarding the report’s summary of use
assignments (Table 2-2), Baumann said the UMR in
In considering UMR
classification, Sullivan said the most difficult boundary to establish is the
one between impounded areas and backwaters. Smogor asked whether the main
channel strata runs through the entire length of the pools. Donnelly confirmed that the main channel
stratum is identified for the entire length of each pool.
Smogor asked that the report
clarify its description of EMAP-GRE sampling to say that one sample was
collected from each site over the course of a three year period.
Hokanson asked WQTF members
for input regarding the draft’s comparison of water data to “threshold” values,
given the further explanation of these values that was added to the beginning
of Chapter 4 in response to discussion at the prior WQTF meeting. Hokanson said Dkhili’s comments on the
current draft indicate some continued discomfort with the use of
thresholds. Smogor said one issue might
be that, as the report later makes clear, dissolved oxygen (DO) levels below
5.0 mg/l in backwaters may not necessarily be detrimental to fish
populations. Hagerty said it is
important for the report to highlight that DO levels below 5.0 mg/l can be a
natural part of the system’s function.
Smogor said that, overall, the threshold comparisons don’t change much
about the report’s bottom line, cautioning also to avoid the use of the word
violation in making any threshold comparisons.
Good said the comparisons are
helpful in highlighting water quality patterns, as long as it is explained that
this is simply for comparative purposes and does not imply a regulatory
decision regarding impairment. Coffey
said the comparison to thresholds could potentially be a distraction from the
report’s larger points about water quality and biological patterns. Lotthammer and Sullivan, however, supported
retaining the threshold comparisons, with Sullivan observing that, without the
highlighting on the data tables showing these comparisons, the data summaries
would not have stood out.
Sullivan observed that, based
on biological information, there might not be a compelling reason to keep the
main channel and side channels separate in a classification system. He emphasized that the most important part is
to separate out backwaters. Sullivan
said limiting the number of classes is also a practical consideration. Donnelly responded that the strata
classifications could be merged in the future as supported by the data.
Hagerty requested that the
designation
Donnelly next described the
proposed classification system contained in the report, which has three
longitudinal classifications (upper impounded, lower impounded, and open river
reaches) and four lateral classifications (main channel, side channel,
impounded, and contiguous backwater).
She added that the classification structure does not address seasonal
differences, but said this should be considered in the development of criteria
for the classes. Sullivan agreed with
the importance of developing criteria for the classes.
Sullivan said the report
should consistently identify the lower impounded reach as ending at the
Smogor asked whether the
floodplain reaches (i.e., upper impounded, lower impounded, open river) are
based on geomorphology or human modifications.
Hagerty replied that the floodplain reaches were based primarily on
geomorphology.
Smogor said investigations of
this type will often examine questions of what is reversible vs. irreversible
in terms of human impacts. Donnelly said
her effort only looked at post-dam data and characteristics. Smogor emphasized the need to separate out
natural and irreversible conditions from reversible conditions in discussing
attainment. Hagerty said similar
questions are also apparent in an LTRMP context. Matt Short observed that one of the
challenges is implementing the CWA in an altered, actively managed system. Chris Yoder said that the CWA requires that
attainable targets be set, but that what is attainable changes over time.
Review of Major Findings and
Recommendations
Good said the important issue
to consider right now is whether the proposed classification structure is what
the WQTF wants to see. Coffey asked
whether other large aquatic ecosystems had dealt with the kind of lateral
diversity present on the UMR. Donnelly
said most are not as diverse, except for those areas impacted by tidal
effects. Yoder observed that the
Good said one of his concerns
is having enough data to do assessments in all of the “boxes” set out in the
classification framework. He also said
aerial photos show that the aquatic areas are spatially complex, so it may be
hard to define distinctions between classes.
Olson responded by saying that the LTRMP probabilistic design gives a
place to start in terms of a monitoring framework. Smogor asked how assessments would be done
with a probabilistic sampling approach.
Olson responded that the assessment would also have to be probabilistic
in nature.
Sullivan concurred with
Olson’s comments, saying that the LTRMP stratified random sampling (
Short said part of the
process here is deciding on how to quantify areas spatially. He noted that rivers are typically assessed
by mile and lakes by acres, but that the UMR doesn’t fit either of these
approaches very well. Smogor asked what
would be done if certain areas along a lateral cross section are impaired and
others are not. Donnelly replied that
this would be analogous to how assessments are done for lakes, where results
from sampling locations may differ.
Lotthammer said the states
should articulate a common vision for how to proceed, while also recognizing
that they will not advance in lockstep.
She added that, if the classification structure is a shared model, it
will also help the states in prioritizing their activities. Sullivan emphasized
that the most important thing is to proceed in identifying strata, with the
recognition that samples won’t necessarily be collected in every backwater, for
example. He continued by saying that
defining a classification system now must also be done with a recognition that
the classes may change as more information becomes available, such as updating
of the LTRMP
Short said the important
thing is to get off the dime with some kind of approach. As criteria are developed, Short said boxes
could be collapsed if criteria do not end up being distinct. He continued by saying that the proposed
classification structure looks like a good starting point. Hagerty said Dan Wilcox’s 1993 paper details
habitat classifications for the UMR.
Donnelly and Hokanson replied that this paper was part of the materials
reviewed in putting together the project and the report. Hagerty said that, while separating out side
channels in upper reaches adds complexity to the classification system, these
areas are vital habitats in the lower reaches and therefore merit distinct
consideration.
Sullivan said, in the
interest of moving forward, he is willing to set aside his concerns about
treating the main channel and side channels separately. He added that he sees some advantage in
mirroring how the states already break up their waterbodies into lakes,
streams, and wetlands, and thus raised the issue to encourage consideration of
this approach in establishing the UMR classification structure. Sullivan said that, with this acknowledged as
an issue for future consideration, he is comfortable with a lateral scheme
based on four LTRMP strata. Yoder
observed that states take many approaches in classifying waterbodies, ranging
from lumping all lotic systems together to having 5-6 classifications. He added that the merits of establishing a
classification structure are great, particularly when it is done using a
systemic UMR perspective. Dkhili said
the four strata distinctions seem especially conducive to criteria-setting, but
that it will cause assessment to be more complex.
Hokanson said his sense from
the discussions is that the WQTF is comfortable moving forward using the
proposed classification structure. WQTF
members expressed their concurrence with the use of the proposed classification
structure (i.e., three longitudinal strata and four latitudinal strata).
Discussion of Next Steps and
Implementation
Good asked about next steps,
given that the WQTF has expressed concurrence on the classification
structure. He asked whether the next
step is to work on tools for unified assessment within the classification
framework. Olson replied that this is
exactly what the biological assessment project is doing for the main channel classification. Smogor said it makes sense to move forward
where the most information is available.
Bouchard concurred, saying that a main channel assessment would seem to
be the most likely place to work. He
said main channel assessment should move forward as soon as possible and then
expand to other strata as knowledge about these areas increases. Donnelly suggested developing a monitoring
strategy that addresses all classes, noting that the tools are already
available for a main channel assessment.
Sullivan said he assumes some type of probabilistic method will be
employed, but that the states still need to decide exactly how this will be
done.
Hagerty asked whether an
assessment couldn’t already be done using existing data, particularly that from
the LTRMP. Sullivan replied that this is
already happening via the bioassessment project, but that a sustainable
monitoring strategy has to be practical and involve identifying priorities, as
it doesn’t seem realistic to expand the intensity of LTRMP monitoring to all
the pools of the UMR. For example, he
said we may find that protecting the main channel results in protection of the
off-channel areas.
Good said he thinks it is
important to express priorities.
Hokanson suggested that perhaps this is best done in a separate,
companion document to the report.
Lotthammer concurred with using a separate document to lay out
priorities, adding that the classification framework helps direct the
monitoring strategy development.
Donnelly agreed, saying that the priorities document could then be updated
as work advanced. Yoder suggested that
his bioassessment work may help inform priorities for monitoring strategy
development.
Sullivan commented that it
may be worth considering how to address the
Report and Project Finalization
Naramore said the entire
report can be sent out to the WQTF for review if that is what the WQTF
wants. Smogor, Short, and Baumann all
requested that the full report be sent out as soon as possible for WQTF
review. All agreed to this, with
UMR CWA Biological Assessment Guidance
Document Project
Presentation of Preliminary Biological
Assessment Report/Data Summary
Yoder gave a presentation summarizing
recent work on the project, as reflected in the interim report Preliminary Analysis of Biological
Assessment Thresholds for Determining Aquatic Life Use Attainment Status in the
Upper Mississippi River Mainstem. He
said this report was added as a project work task following the second work
session, noting that the following elements of the proposed guidance content
are addressed at least in part by this report:
Yoder said the advantages of
conducting the preliminary thresholds report’s analyses include: 1) gaining
practical experience and testing indices by doing an “assessment”, and 2)
developing the guidance around lessons learned from conducting the analyses and
“assessment,” including recommendations for attainment thresholds. He emphasized that the report presents an
object lesson in what a biological assessment process for the UMR might entail,
but is not itself the only or final approach to conducting a UMR biological
assessment.
Yoder described the
methodology used in the report as follows:
He added that another
approach, the biological condition gradient (BCG), would involve “constructing”
biological assemblage attributes along an entire gradient of potential
quality. He stated that this approach
would require addition effort, but would likely be very worthwhile for the
longer term and would reinforce TALU approaches.
Yoder said
Yoder closed his presentation
by making the following preliminary observations:
Discussion of Data Analysis Outcomes and
CWA Attainment Thresholds for the UMR
Sullivan asked whether the
comparison made with the lower St. Croix River included
Karen Hagerty asked why
non-indigenous fish were not included as one of the metrics in the Open River
GRFIn. Mark Pearson replied that numbers
for non-indigenous fish are highly variable.
Ted Angradi added that the
stressor gradient was now a bit dated and if it was going to be employed in CWA
decision-making, it should probably be updated.
Yoder cautioned the group not
to get too wrapped up in details regarding the EMAP-GRE indices because, while
these are also important, the biggest need is for the WQTF to consider the
broader implications of moving to biological thresholds and biologically-based
impairment decisions.
Yoder asked Dave Bolgrien if
the state-specific results presented in Table 2 of the preliminary thresholds
report matched the analyses done by EMAP-GRE.
Bolgrien said that these looked close to what EMAP-GRE staff have
seen.
Yoder stated that proximate
stressors can sometimes be proxies for other stressors, but at least the
identification of proximate stressors can point in the right direction
regarding causes of impairment.
Bouchard asked if enough
information is available to create a BCG.
Yoder replied that this would need to be investigated via a cursory
desktop BCG effort, at least initially.
He said one question such an analysis could answer is whether setting a
threshold based on the “best available UMR” may be setting the bar too
low. Yoder added that some sites on the
UMR may actually warrant an exceptional classification. He said other regional river data could be
utilized in setting up a BCG.
Sullivan asked what the
sample size was for other rivers used in the comparative analysis. Yoder said there are at least 30 samples per
river. Sullivan also asked about the
extent of the
Roy Smogor asked whether the
EMAP-GRE approaches depended on the stressor gradient developed by EMAP. Yoder replied that this is the case. Smogor said it is important to consider
whether the stressor gradient is a good representation of human-caused
stress. Yoder acknowledged Smogor’s
point, but stressed that the most important thing is that the indices are
directionally correct in their function, as often just 50-60 percent of the
maximum scale is considered as meeting an attainment threshold.
Sullivan asked Yoder whether
the FACI and GRFIn were compared on the UMR.
Yoder replied that this had been done, with some similarities and some
differences seen. Sullivan again asked
whether the highest scoring UMR reach can be used as an internal reference
condition.
Smogor requested that the
Region 5 document including the FACI be made available. Yoder said this can be done, but cautioned
that the FACI has not yet been published.
Yoder asked the EMAP-GRE
staff whether they had any other comments regarding the thresholds report. Angradi said the characterization of EMAP-GRE
data appeared appropriate. Bolgrien
reiterated that the metric selection in the indices did not include any a priori decisions, but rather was based
on relationship to the stressor gradient, following the methods of Karen
Blocksom. Bolgrien and Angradi also
cautioned that reference conditions may not exist on the UMR. Sullivan asked whether any other indices were
expected soon from EMAP-GRE work.
Angradi said a diatom index, related to nutrients, is expected out
soon.
Tom Wilton asked whether it
is possible to create separate BCGs for each of the UMR’s floodplain
reaches. He said some of the higher
scoring sites on the lower portion of the impounded river and the open river
may indicate that a higher condition, similar to that on the upper impounded
river, may actually be attainable.
Yoder commented that only
three macroinvertebrate sites met the least disturbed condition threshold. Hagerty added that the GRMIn appears fairly
flat relative to the stressor gradient.
Yoder concurred, but said he would like to talk further with EMAP-GRE
staff about this.
Sullivan asked whether
threshold-setting is ultimately a policy decision, recognizing that
pre-settlement conditions are never going to be possible. Yoder said the cleanest way to establish a
threshold is to have a reference that reflects least impacted conditions. However, he added, this is not possible for
the UMR and therefore an information-based alternative is needed.
Yoder said it might be
possible to create more condition classes out of the EMAP-GRE approach, but
that it is not clear that five or six condition classes could be created. Sullivan repeated his suggestion that using
an internal reference, such as the 95th percentile of EMAP UMR data,
might be preferable to using a reference based on regional data that might not
be applicable to the UMR. Yoder
cautioned that such an approach might end up setting the bar too high. Sullivan replied that his preference would be
to potentially set the bar too high using internal data, rather than using data
that may not be applicable. Yoder said
there is no “silver bullet” and that the EMAP stressor gradient is about as
empirical as it gets, lacking an existing reference condition.
Smogor asked whether there
has been any effort to look at GRFIn’s precision. Angradi and Bolgrien said they did not think
so, with Angradi reminding the group that the stressor gradient likely needs to
be updated. Bouchard asked if the EMAP
data could be revisited to calculate the precision of GRMIn scores. Yoder said this could be done, but may not
be the most desirable way of examining GRMIn.
Hagerty said invasive species can make up a large part of total biomass
in some areas, and therefore should likely be included as a GRFIn metric.
Yoder urged the group to
consider that a biological approach is very likely to increase the number of
non-attainment reaches.
Sullivan asked whether a
decision had been made on the sampling design to be used, presumably between
EMAP or LTRMP. Yoder said work done by
Bartels and Dukerschein showed a fair amount of equivalency between these
programs, and possibly with MPCA’s approach, but that WI
Yoder asked group members if
they want the final guidance to include a statement regarding which programs
are adequate to the task and what tweaks might be needed. Hokanson replied that this is definitely in
the scope of work. Yoder observed that,
in cases of competing methodologies, people and programs are typically
reluctant to drop their methodology. He
said the question then becomes equivalency and that even with the work done by
Bartels and Dukerschein, the equivalency question has not yet been fully
settled for UMR methods.
The meeting adjourned for the
day at
Discussion of Data Analysis Outcomes and
CWA Attainment Thresholds for the UMR (Continued)
The meeting’s second day
began with a resumption of the discussion regarding the preliminary thresholds
report. Olson said he had concerns with
the stressor gradient being highly manufactured and as such he is not confident
that it is a good indicator of biological condition. Hagerty said she would like to learn more
about how the metrics for the GRFIn were chosen. Smogor said he also has reservations about
the stressor gradient, but feels that it likely does a good job overall in
portraying condition.
Yoder said the comparisons to
regional indices give him increased confidence in the EMAP-GRE indices. He asked the group whether, if there are
problems with the stressor gradient, it is up to the WQTF to address these
problems. He added that, if that is
something the group wishes to be addressed in the current project, it is important
to know that sooner rather than later.
Yoder also said the group needs to keep in mind that much of this effort
is directed toward identifying directionally correct indicators and not
necessarily precise numbers.
Smogor suggested that one
helpful step might be to ground truth the EMAP-GRE results by showing them to
individuals who know the river best.
Olson said some of these individuals were involved in the EMAP process,
including in the selection of least impacted sites. Sullivan said there had been a concern about
bias in involving river experts in the process.
Smogor said this expertise is exactly what is needed, however. Yoder stated that a mixture of both
expertise and independence is important.
Sullivan said the information
coming out of the threshold analysis seems to make sense in comparison to work
done by Wisconsin
Yoder agreed that the
macroinvertebrate index appears to be compressed and said one of the concerns
with GRMIn is that it may not be able to recognize high quality sites. However, he said recalibrating an index would
seem to be beyond the scope of work for this project. Hokanson agreed that the project scope is to
examine existing tools and identify strengths and limitations, but not
necessarily to fix them.
Hagerty said the limitations
in GRMIn may hold back buy-in from the natural resource managers, and that the
group needs to consider how important this buy-in is to them. Sullivan said no index will be liked by all
parties, as all indices have their biases.
Yoder said resource managers have often voiced concerns about
multimetric indices. Good asked whether
Yoder felt that managers have been incorrect in their opposition to multimetric
indices. Yoder replied that, in his
opinion, multimetric indices are tools that work.
Good said he is hearing that
the group is more comfortable with GRFIn than GRMIn. He continued by saying it is important for an
Lotthammer asked whether the
results indicate that the indices might be okay, but that the data set is
limited. Yoder replied that this also is
a possibility. Bouchard commented that
the limited spread in the macroinvertebrate results might actually be a fair
representation of conditions. Yoder said
one of his jobs is to inform the WQTF on how serious the problems with GRMIn
might be.
Bouchard asked what the
comparability of macroinvertebrate protocols is between agencies. Yoder replied that there are not really many
currently viable options, aside from EMAP-GRE.
He added that the Metropolitan Council’s approach used artificial
substrate and as such is not very comparable to EMAP-GRE. Sullivan said macroinvertebrate sampling
costs may be relatively high. Yoder
said he has found, fish and macroinvertebrate costs to be generally comparable,
as fish costs are high for equipment and labor, while laboratory analysis costs
are more for macroinvertebrates.
Smogor asked whether, to
provide a degree of comfort, it might be possible to generate GRFIn scores for
the regional rivers used in the FACI.
Yoder replied that this would require extracting FACI data and running it
through the GRFIn. Hagerty said it was
very likely that there would be differences in the FACI and the GRFIn outcomes
for the
Olson said he wasn’t sure
that he agreed with EMAP’s conclusion of two longitudinal strata and that there
may need to be separate indices for Upper Impounded, Lower Impounded, and
Yoder said it is clear from
the discussion that the group is not currently comfortable with the indices and
their mechanics. He suggested that a
next step is a first order analysis of the available indices, but cautioned
that this may result in a desire to build new indices. Smogor said he believes the EMAP-GRE indices
are likely sound, but reiterated his suggestion for further ground
truthing. Yoder said the approaches
being discussed are as sound as what is being used elsewhere. He cautioned that discussion of the stressor
gradient risks becoming a distraction, emphasizing that it really only needs to
be directionally correct and that from there the biology can do the heavy
lifting.
Hokanson said it is likely
other stakeholders will want to see the ground truthing Smogor suggests. He added that his concern is the ability to
communicate the approach to the public, noting that even the WQTF is having
trouble understanding the stressor gradient and the EMAP-GRE indices. Yoder replied that, in communicating to the
public or stakeholders, the emphasis is on explaining that you used a valid
methodology, but not getting into all the mechanics or details.
Lotthammer asked how the
EMAP-GRE indices’ two longitudinal strata approach can be reconciled with the
three longitudinal strata system just laid out in the ALDU discussion.
Good observed that there is
no mechanism or plan in place to repeat EMAP-GRE monitoring. He further asked if EMAP-GRE was intended at
its outset to provide a CWA assessment of the river. Yoder replied that this seems to be the
intent of the program, even if not stated outright. Smogor concurred, adding that EMAP-GRE staff have never stated this directly. Yoder said the work this WQTF project is
doing bridges from the EMAP effort to an actual CWA assessment.
Lotthammer said that, before
these approaches are implemented for CWA assessment, there needs to be more
consideration of the implications, including TMDLs and how to address the
ability to monitor for response. Hagerty
said she is concerned by the abrupt change in threshold at the juncture of the
Lower Impounded Reach and the
Good asked whether the current
project would produce a binding assessment that would then have to be used in a
303(d) setting. Yoder said the EMAP-GRE
monitoring program and data are generally good and produce results in line with
common practices. He continued by saying
that the challenges are really in dealing with implications, and that this is
common when biology is brought into the assessment process. Sullivan said that, while the results may not
be perfect, they are much better than what is currently being done.
Good reiterated his concern
with what comes next, in terms of use in 305(b) assessments and 303(d)
impairment listings. Lotthammer
concurred, saying that one of the questions is how to characterize the results
of the current work as “here’s how an assessment could be done” vs. “here’s how we did an assessment.” Hokanson
stated that actually conducting a CWA assessment is beyond the original project
scope of work, but that the WQTF could alter that scope if desired. Yoder concurred, but added that it is not a big
step from figuring out how to do an assessment to actually characterizing the
results as an assessment.
Good and Lotthammer
reiterated their concerns about the potential use of the report outcomes. Bill Franz said he would also need to consult
within EPA on this matter. Smogor
emphasized that the outcomes really depend on where the threshold of attainment
is established. Olson observed that a
lot also depends on what is chosen as a determination of impairment (e.g., 10%
of sites not meeting a threshold and/or certain frequency in which threshold
not met) once a particular threshold value has been selected. Sullivan commented that EMAP has not to date
released its final report, so in a sense all analyses conducted using EMAP may
be considered preliminary.
Yoder invited the WQTF to
further consider both the science questions and the implications of applying
biology in CWA assessment, and send any comments to him. He also emphasized a need to address the
question of continued monitoring. Lotthammer
concurred that there needs to be greater discussion of implementation
considerations within the scope of the project.
Hokanson said addressing implementation issues is clearly within the
scope of the project. Sullivan said it
is important to express a plan in the guidance, even if current resources do
not allow for its immediate implementation.
Lotthammer said she would
like to the guidance to comment both on what’s available and where things need
to go in the future. Good said it is
important not to be painted into a corner with the guidance, and not to portray
that it represents a 305(b) assessment or 303(d) impairment listing. He said one approach to mitigate this could
be to offer multiple examples, which presumably would have varied outcomes. Yoder said the downside to this is the
appearance of hunting for an answer, and that the process is not that
subjective and needs to be an informed decision-making process. Smogor and Sullivan said that, by its very
nature, a guidance does not bind the states to accept the methodology or the
outcomes.
Hokanson and Yoder suggested
that, since all the technical and policy questions clearly would not be
resolved in this meeting, further action steps are needed. They proposed that Yoder integrate additional
analyses into the thresholds document and then circulate this to the WQTF in
February 2011, with the WQTF then holding a conference call to discuss the
revisions in March before the guidance is distributed to the broader
participant group in April. The WQTF
concurred with this approach. Hokanson
thanked Yoder for all the work done to date on the project.
UMR Monitoring Strategy Proposal
Hokanson distributed a
proposal for the development of a UMR CWA Monitoring Strategy that Illinois EPA
had incorporated into its FY 2011 Section 106 supplemental monitoring
application. Good explained that this
presents an unexpected opportunity to build on the WQTF’s work. He stressed that this proposal responds to
recommendations in the ALDU report and elsewhere to develop a comprehensive CWA
strategy for the UMR. He emphasized
that, although the project would be funded via
Donnelly said that, from an
EPA perspective, the initial proposal needs more specifics and that the 2 year
proposed timeline seems long. Good said
he would continue to work with EPA to refine the proposal. He also said two years is reasonable given
the scope and multiple entities involved.
Hokanson concurred, saying that the process of mutual discussion,
understanding, and concurrence with a plan is what really takes time, as
opposed to just technical details.
Good said he envisions this
effort as being similar to what the states need to develop for their own
monitoring strategies. Yoder observed
that this effort crosses paths with the biological assessment guidance work.
Donnelly asked whether the
strategy would cover just the main channel or all strata. Good said that main channel would be highest
priority. Naramore added that all strata
would be considered in the strategy.
Sullivan said his assumption is that the strategy would not be down to
the level of picking individual sites, but would address questions of frequency
and site selection, such as are in the existing EMAP documentation.
Donnelly asked whether, if a
strategy were to be developed, the states would be obligated to implement
it. Good and Lotthammer said it would be
dependent on resources being available, as is the case with monitoring
strategies generally.
Good requested WQTF members
to provide him with any other comments on the monitoring strategy as soon as
possible.
UMR Human
Health Uses Discussion
Hokanson gave a brief status
update on the UMR Human Health Uses discussion, reminding the group that this
was an outgrowth of the previous year’s draft arsenic TMDL proposed by US EPA
Region 7. He noted that most of the
discussion in the group has focused on arsenic-specific issues, as opposed to
human health-related issues more broadly.
Donnelly asked about the
purpose of the discussions. Hokanson
replied that the effort is primarily focused on issue identification related to
arsenic and human health uses generally, and is not scoped to necessarily
resolve the issues that are identified.
Dkhili said he hopes the discussions will aid in developing approaches
to address naturally occurring contaminants under the CWA. He added that it would also be beneficial if
these discussions contributed to a more consistent approach to human health
protection on the UMR among the states.
Interstate 305(b) Assessment and 303(d)
Impairment Listing Consultation
Hokanson displayed UMRBA’s current
comparison of the states’ listings for the UMR.
Each state provided comments on its assessment and listings as follows:
Good said Illinois EPA
continues to be in discussions with US EPA Region 5 regarding its 2008 and 2010
303(d) lists. He said the 2008 list has
been partially approved and no action has yet been taken on the 2010 list.
Olson reported that
Sullivan said the UMRBA chart
appears to correctly reflect
Lotthammer said UMRBA’s
characterization of
Dkhili said he was not sure
whether US EPA Region 7 had approved
Franz said he had no further
comments to offer on behalf of US EPA.
Emerging Issues for Listing
Sullivan said
Olson said he plans to argue
against a single-sample listing related to the presence of indicator bacteria
(fecal coliform), as existing guidance from US EPA appears to favor the use of
a geometric mean, even though this has not been encouraged by US EPA Region 7
staff. Short said
Lotthammer said
Other Agency and Organization Updates
Good said that
Olson said an ongoing issue
is
Dkhili said Missouri
Lotthammer said MPCA is
completing a report on endocrine disruptors near wastewater treatment plants on
Bob Buchmiller said the new
USGS Iowa Water Science Center Director is Kevin Richards. Buchmiller said USGS has also reorganized
such that
Sullivan said UMRCC’s-Water
Quality Tech Section will meet next on
Franz said Tom Davenport of
US EPA Region 5 is developing a workshop to address statewide nutrient
reduction strategies. Buchmiller asked
whether this workshop would be web-based or in-person only. Franz replied that his understanding is that
it is an in-person only meeting.
Naramore commented that, due
to new governors and retirements, there is significant turnover on the UMRBA
Board. She said staff will keep the WQTF
updated as representation is settled.
Donnelly asked when the
nutrient-related workshops under the 604(b) project would be held. Naramore replied that these would take place
during the summer, so that the workshops report can be completed by
Confirming Priorities and Next Steps
Hokanson
summarized the following next steps for the WQTF:
Good asked that Hokanson
distribute these next steps via email to the WQTF following the meeting.
The meeting adjourned at