Water Quality:

Key EPA and State Decisions Limited by Inconsistent and Incomplete Data

RCED-00-54: Published: Mar 15, 2000. Publicly Released: Mar 22, 2000.

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Pursuant to a congressional request, GAO provided information on the Environmental Protection Agency's (EPA) National Water Quality Inventory, focusing on whether: (1) the information in EPA's National Water Quality Inventory is reliable and representative of water quality conditions nationwide; and (2) available data are sufficient to allow state officials to make key decisions about activities required by the Clean Water Act, such as identifying waters that do not meet water quality standards and developing strategies to address those waters.

GAO noted that: (1) the National Water Quality Inventory does not accurately portray water quality conditions nationwide; (2) a major reason is that it would be cost-prohibitive to physically monitor all of the waters in the country, and, therefore, almost all states monitor a subset of their waters; (3) most monitoring is not done in a way that allows for statistically valid assessments of water quality conditions in unmonitored waters; (4) the Inventory is not reliable because wide variation exists in: (a) the way that individual states select their monitoring sites; (b) the kinds of tests they perform on their waters and how the results of these tests are interpreted; and (c) the methods they use to determine the causes and sources of pollution in waters that do not meet water quality standards; (5) as a result, the information in the Inventory cannot be meaningfully compared across states; (6) EPA used information from the Inventory as a basis for a number of important decisions and activities, such as deciding how to allocate federal funds for Clean Water Act programs to states and measuring and communicating EPA's and states' progress in implementing the act; (7) the dearth of the waters actually monitored, combined with the wide variation among states' monitoring and assessment approaches, make the national statistics unreliable and subject to misinterpretation and, therefore of limited usefulness for these purposes; (8) there is little doubt among experts that the remaining problems are considerable and that solutions will entail significant expenditures; (9) what is uncertain is the precise extent of water quality problems, where and what the most severe problems are, and the location of high-quality waters that need to be protected; (10) the limitations of the information in the Inventory extend well beyond the problems associated with the national uses of the report; (11) state-level activities, such as identifying water quality problems and setting priorities among them to obtain the most improvement in water quality for the dollar spent, are also affected by data limitations; (12) GAO's survey shows that data gaps limit states' abilities to carry out several key management and regulatory activities on water quality; (13) only six states reported that they have a majority of the data they need to assess whether their waters meet water quality standards; and (14) a vast majority of states reported that they have less than half the data they need to: (a) identify nonpoint sources that are causing waters not to meet standards; and (b) develop total maximum daily loads (TMDL) for those waters.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA's TMDL Tracking System is the agency's primary system for documenting key information regarding the TMDL program. The system maintains information on completed TMDLs and includes links to each individual TMDL. Users can access the system through EPA's TMDL webpage.

    Recommendation: To facilitate more efficient information sharing regarding TMDL development, the Administrator, EPA, should expand the dissemination of its TMDL library. A first step should be for EPA to routinely send the list of TMDLs in the library to states, as well as to regions and to consider automating the library to facilitate more efficient access to the information.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: EPA held four TMDL forums in 2001, with the purpose of providing technical exchange and identifying complex technical and policy issues confronting states and the TMDL program. EPA also holds regular technical conference calls with the states that focus on topics the states have identified as most pressing. EPA is using the information gathered during these sessions on technical needs to update their strategic plan for technical support.

    Recommendation: The Administrator, EPA, should finalize the agency's strategy for supporting TMDL development. As a part of this process, EPA should continue working with states and other stakeholder groups, as well as gather information on states' requests for technical assistance from headquarters, regions, and labs to obtain the most complete picture of states' needs as possible.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: EPA is taking a number of steps to address issues related to inconsistencies in state water quality data and facilitate better use of data from other sources. Of particular importance, EPA has developed a guidance document on the elements of an adequate state monitoring program that it intends to use to implement monitoring provisions of section 106 grants. The guidance was released in March 2003, and is entitled "Elements of an Adequate State Monitoring Program."

    Recommendation: The Administrator, EPA, should take actions to more appropriately characterize state-reported information and more effectively use other available water quality data in the National Water Quality Inventory. Specifically, the Administrator should reexamine the implications of relying on the report's data for use in national decisions and communications to the public. Specifically, the Administrator should do the following: (1) evaluate the potential impacts of inconsistent data on the extent of pollution in states on the allocation of the Clean Water Act's section 106 grant funds to states, determine what data are needed to reliably support allocations, and develop a plan for ensuring that such data will be developed and used; (2) identify the information that EPA will use for establishing a baseline of water quality conditions and measuring progress toward the goal of having 75 percent of U.S. waters supporting healthy aquatic communities and develop a plan to ensure that reliable information will be obtained and used; and (3) evaluate the implications of using these data to generate an indicator of the quality of watersheds in the Index of Watershed Indicators and take any corrective actions needed to reliably represent water quality conditions.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Implemented

    Comments: In the 1998 National Water Quality Inventory (published in 2000), EPA included information on the results of a U.S. Geological Survey program on the level of nutrients in selected waters across the country. EPA plans to continue to include additional sources of water quality information in future reports.

    Recommendation: The Administrator, EPA, should take actions to more appropriately characterize state-reported information and more effectively use other available water quality data in the National Water Quality Inventory. Specifically, the Administrator should supplement the information in the Inventory by integrating, where appropriate, the findings from other programs to support or explain state-reported information. These programs include EPA's Environmental Monitoring and Assessment Program, the U.S. Geological Survey's National Water Quality Assessment Program, and others.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed - Implemented

    Comments: The 1998 Water Quality Inventory (published in 2000) specifically highlighted the amount of waters actually monitored for this report to help avoid confusion that the report speaks to all waters nationwide. EPA also discusses in the report the implication of different water quality standards and assessments on the aggregation and comparison of water quality results.

    Recommendation: The Administrator, EPA, should take actions to more appropriately characterize state-reported information and more effectively use other available water quality data in the National Water Quality Inventory. Specifically, the Administrator should better convey the report's limitations in characterizing the nation's water quality by more clearly identifying: (1) the percentage of waters that are actually monitored and the resulting assessments of quality; and (2) the similarities and differences among states' water quality standards and monitoring and assessment methods, and the implications of these differences on nationally aggregated information.

    Agency Affected: Environmental Protection Agency

  6. Status: Closed - Implemented

    Comments: EPA has developed guidance for promoting more consistency in data collection and decision criteria used to make water quality assessments. The Office of Water provided guidance, entitled "Elements of an Adequate State Monitoring Program," in March 2003, for states and EPA to use in developing state strategies and milestones for upgrading state monitoring programs over a 10-year period. The Office of Water also issued the 2002 Integrated Water Quality Monitoring and Assessment Report Guidance, which called for combining the section 305(b) reports and section 303(d) lists of impaired waters. EPA is also working with its partners to develop a national strategy that will guide EPA actions over the next several years as it seeks to improve state programs, data management systems, and the scientific defensibility of the data and information. EPA plans to complete this strategy by 2005. EPA expects that these activities will facilitate comparison and understanding of differences among state-reported water quality information.

    Recommendation: The Administrator, EPA, should take actions to more appropriately characterize state-reported information and more effectively use other available water quality data in the National Water Quality Inventory. Specifically, the Administrator should identify other ways of aggregating state-reported information that take into consideration the inconsistencies between states' programs in order to minimize the potential for misuse and misinterpretation.

    Agency Affected: Environmental Protection Agency

  7. Status: Closed - Implemented

    Comments: EPA holds regular conference calls (e.g., every several weeks) with EPA regions and states to discuss TMDL technical and policy challenges. The topics for discussion are decided by the group and reflect the most pressing challenges at the time.

    Recommendation: As part of its overall strategy, the Administrator, EPA, should establish a process for systematically tracking states' requests for technical tools and assistance and how these requests are addressed, on a routine basis, to ensure that it is addressing needs efficiently and to stay abreast of changing needs.

    Agency Affected: Environmental Protection Agency

 

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