Many Water Quality Standard Violations May Not Be Significant Enough To Justify Costly Preventive Actions

CED-80-86: Published: Jul 2, 1980. Publicly Released: Jul 2, 1980.

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The Environmental Protection Agency (EPA) administers a Construction Grants Program under the Water Pollution Control Act to restore and maintain the quality of the Nation's waters. EPA estimates that $10 billion will be needed through the year 2000 to construct advanced wastewater treatment (AWT) facilities for municipal sewage for the program. GAO discussed wastewater treatment with federal and state water quality officials and consultants in the field. Each state has developed water quality standards to protect its waterways and their uses. The standards help determine the type of wastewater treatment needed to protect waters for those uses. AWT, which may be required in municipalities, is very expensive. Violation of a water quality standard may not always mean that significant environmental, social, or public health damage has occurred. The scientific basis for the standard may be questionable, and the water may not be important to society. In many instances, municipalities are constructing treatment facilities which are more sophisticated than necessary to prevent predicted water quality standard violations. The mathematical models, upon which these predictions are based, produce highly uncertain results. The law does not require communities to consider adequately the costs of achieving water quality standards. An agency analysis of nine projects did not show the significance of the projects' AWT to the environment, its effect on public health, its significance of the on established waterway uses, or the social significance or benefits of the projects.

GAO found that the water quality standard setting process is questionable, modeling to determine violations is often imprecise and inexact, federal funding is insufficient to achieve water quality standards for all waterways within a reasonable period of time, obtaining downward reclassification from EPA is very difficult, and relating the impact of various treatment levels on water uses is difficult. GAO believes that AWT, with few exceptions, may not be justified at this time. GAO concluded that funding of AWT projects should be curtailed. Federal funds should not be spent to provide a level of treatment that produces such uncertain results. These factors affect billions of dollars that have been or will be spent under the EPA Construction Grants Program. The standard setting process places too much emphasis on preventing all types of water quality standard violations rather than just significant violations.

Matter for Congressional Consideration

  1. Status: Closed - Not Implemented

    Comments: Since issuance of the report in 1980, Congress has held oversight hearings and has made many changes to the Clean Water Act. However, the need for cost/benefit reviews on AWT projects has not been a high priority and has not been adopted by Congress.

    Matter: Congress should consider amending the Clean Water Act to: (1) require explicitly a cost/benefits review to show whether AWT will result in significant water quality, social, or public health benefits before such projects can be funded; (2) require the states to do a cost/benefits analysis of effluent limitations more stringent than those required by the act; (3) declare a moratorium on AWT projects by withholding funding for wastewater treatment beyond secondary until EPA can clearly show what ecological, social, and public health benefits are being realized by the various levels of treatment beyond secondary; and (4) eliminate the requirement for a margin of safety which compensates for the lack of knowledge concerning the relationship between effluent limitations and water quality and include language in the act to require that all treatment beyond secondary and costing $1 million or more must produce significant ecological and social or public health improvements.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: While GAO still believes this recommendation is valid, the agency will take no action.

    Recommendation: The Administrator, EPA, should establish criteria to determine the degree of modeling reliability that will be acceptable.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Not Implemented

    Comments: While GAO still believes that this recommendation is valid, the agency will take no action.

    Recommendation: The Administrator, EPA, should require EPA regions to be more consistent in approving variances of water quality standards and downgrading water quality standards.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Not Implemented

    Comments: While GAO still believes that this recommendation is valid, the agency will take no action.

    Recommendation: The Administrator, EPA, should develop specific criteria governing what constitutes an adequate and cost-effective water quality survey for justifying AWT projects.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Not Implemented

    Comments: EPA plans no action to adopt this recommendation.

    Recommendation: The Administrator, EPA, should become more realistic and cost conscious about the attainability of water quality standards when a state has made a reasonable showing that standards are unattainable or too costly to attain. The Administrator should not impede the downgrading process with burdensome evidentiary requirements.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed - Not Implemented

    Comments: EPA plans no action to adopt this recommendation.

    Recommendation: The Administrator, EPA, should reduce the cost criteria for what constitutes an "expensive" sewage plant. To a greater degree, the Administrator should accept state and local views that project costs are not commensurate with benefits.

    Agency Affected: Environmental Protection Agency

  6. Status: Closed - Not Implemented

    Comments: EPA plans no action to adopt this recommendation.

    Recommendation: The Administrator, EPA, should permit variances in reclassification criteria in cases where stream improvement requires treatment beyond secondary to meet water quality standards but where ecological and social or public health improvements are not significant enough to justify the costs of the improvements.

    Agency Affected: Environmental Protection Agency

  7. Status: Closed - Not Implemented

    Comments: EPA plans no action to adopt this recommendation.

    Recommendation: The Administrator, EPA, should require, when AWT is an issue, that at least two thorough surveys of the waterway be done: (1) one for calibrating the mathematical model; and (2) another for verifying the calibrated model.

    Agency Affected: Environmental Protection Agency

  8. Status: Closed - Not Implemented

    Comments: EPA plans no action to adopt this recommendation.

    Recommendation: The Administrator, EPA, should develop material to help decisionmakers know the predictive accuracy of models used to justify AWT and establish minimum requirements for the predictive accuracy of these models.

    Agency Affected: Environmental Protection Agency

  9. Status: Closed - Not Implemented

    Comments: EPA plans no action to adopt this recommendation.

    Recommendation: The Administrator, EPA, should revise the AWT review guidelines or, if necessary, suggest legislative changes to allow revisions to delete the provisions that allow projects: (1) not having significant water quality improvements to be funded because the projects will cost more if they have to be revised or redesigned to delete insignificant treatment processes; (2) to be exempted from the review process if they involve land treatment; and (3) to be exempted from the review process just because the state's definition of "secondary treatment" is more stringent than that of EPA.

    Agency Affected: Environmental Protection Agency

 

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