The relationship between updating water quality standards for toxics and safely enjoying a nice, fish dinner
Why are Washington and Idaho updating their surface water quality standards? And what does that have to do with protecting human health from toxic substances that can build up in fish and shellfish?
And why are local governments and industries that discharge treated wastewater into water bodies concerned that updating these regulations may be unattainable and/or drive up the costs of everything from utility rates to consumer products? Are jobs and economic growth on the line?
Lastly, why are some constituents concerned that the regulations being developed will not be strict enough? Will the most vulnerable be the most at risk?
The answer: it’s complicated.
On March 27th, the conference will provide a forum for both Idaho and Washington to explain what’s going on. Tribal, municipal, industry and environmental stakeholders will provide their perspectives and dialog about what the future may hold.
On Thursday, March 28th from 9 a.m. to 12:30 p.m., the Washington Department of Ecology is also hosting a Policy Forum to gain input and provide much greater detail about Washington’s rule-making (regulatory) efforts. Held at the same location as the conference, registration is free. Click here to register for webinar, or e-mail swqs@ecy.wa.gov to reserve a seat at Center Place.
The issue in a nut shell
Toxic substances such as mercury, metals, pesticides and other organic compounds are ubiquitous in today’s environment. They can get into our waters from any number of sources, e.g– air deposition, agricultural or stormwater runoff, wastewater treatment, etc. Once in the system, contaminants can migrate up the food chain, build-up a presence in fish and shellfish, and then be consumed by you and me.
Depending on what type of fresh and saltwater edibles we’re ingesting and how much, there are potential cancer and non-cancer risk factors that need to be addressed to protect human health.
Both Idaho and Washington currently have human health water quality criteria for toxics; and both states agree these regulations need to be updated to reflect how much people are really eating. The stakes are high.
Once in place new standards will affect which waters are listed as “impaired” and thus subject to stricter water quality regulations. They will also lead to a new generation of permit conditions that can increase costs for local governments and industry needing to discharge treated effluent into water bodies.
A beginner’s guide to issues
Water quality criteria are established by determining the relationship between pollutants in the environment and human health. Regulators think about this relationship by considering two complex set of variables: how much fish people consume, or average grams per day; and the potential effects of diverse chemicals. The higher the combined consumption rate and presence of toxic substances, the more protective the water quality criteria need to be to protect human health.
So how much do people consume? Washington is relying on existing fish consumption survey data, and Idaho is developing a fish consumption survey.
And should the resulting standards be based on populations who consume the most fish? Or should they be based on average fish consumption rates for the general population?
For many Native American tribes with strong cultural ties to the resource and other populations engaged in subsistence fishing, the standard of protection should be based on meeting the health needs of the most vulnerable populations and those most impacted by the quality of surface water.
To make it more complicated, should regulators include store bought and anadromous fish in the calculation? If such an outcome leads to stricter water quality criteria for state surface waters, some question if water quality standards for state surface water are being used to offset individual choices to consume fish from ocean and other non-state waters. Is that fair?
Still others question how to account for regional or watershed differences in consumption rates or the presence of toxic substances.
This is just a sampling of questions and concerns being discussed.
From the perspective of municipalities, industry and others needing to comply with stricter water quality standards, the primary concerns are the potential costs of compliance, the time line for coming into compliance, and availability of technology to meet the new standards.
In both states, addressing these concerns is leading to a parallel process of creating “implementation tools.” The net effect of these tools will be to allow for variances, use of best management practices and other “advanced” techniques to allow dischargers to come into compliance over time.
For Washington, draft rule-making for public review is expected by this fall. In Idaho, rule-making is not likely before 2016.