Airsheds and Watersheds II:
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Airsheds & Watersheds: A Shared Resources Workshop
Raleigh, North Carolina
Executive Summary
The second workshop in a series of workshops
addressing the regional impact of atmospheric nitrogen
deposition on east and gulf coast estuarine
eutrophication was conducted in Raleigh, North
Carolina, March 5-7, 1997. The view adopted is that
the atmosphere constitutes a "shared resource"
carrying pollutants that affect many ecosystems, some
greatly more than others.
The Raleigh workshop evolved out of an
understanding that the resources we enjoy and protect
cross over geographic regions and political boundaries,
and that responsibility for them is shared among
agencies and states. Any improvements in air quality
from implementation of the Clean Air Act
Amendments of 1990 or other efforts will have
widespread benefits, including reduced input of
atmospheric nitrogen compounds to coastal
ecosystems.
Current estimates indicate that a significant fraction of
the total nitrogen entering coastal and estuarine
ecosystems along the Eastern U.S. arises from
atmospheric deposition; however, the exact role of
atmospherically derived nitrogen compounds in the
decline of the health of coastal, estuarine, and inland
waters is still uncertain. From the perspective of
coastal ecosystem eutrophication, nitrogen compounds
from the air, along with nitrogen species from sewage,
industrial effluent, and fertilizers, become a source of
nutrients to the receiving aquatic ecosystem.
Eutrophication, however, is only one of the detrimental
impacts of the emission of nitrogen containing
compounds to the atmosphere. Other adverse effects
include the production of ground-level ozone, acid
deposition, and decreased visibility (photochemical
smog). The specialized scientific disciplines involved
in this issue are striving to reduce the associated
uncertainties, and to develop a broad-based
understanding of the cross-media problem so that
issues can be addressed at a national level, rather than
as site-specific case studies.
There were three broad objectives for this workshop:
1. To determine the essential connections between
issues, programs, agencies, organizations and
jurisdictions which would advance our ability to
address the atmospheric nitrogen issue.
2. To identify and/or create new platforms for
discussion of solutions.
3. To identify management issues around which
additional research and policy work are needed to
advance our understanding of the ecosystem impacts of
nitrogen as it moves between airsheds and watersheds.
The first "shared resources" workshop on the role of
atmospheric nitrogen deposition was held in October
1995 at the Airlie House in Warrenton, Virginia (the
"Airlie Workshop"). Many of the questions addressed
at that time were, by necessity, carried forward to the
Raleigh workshop. Additionally, a list of research
priorities, developed at an earlier meeting in 1994
(The "Mt. Washington Workshop") and subsequently
endorsed at the Airlie Workshop, was also carried
forward to the Raleigh workshop. The following is a
summary of the list:
Participants at the Raleigh workshop endorsed each of
these priority items, and added two more:
The meeting was designed as a sequential series of
interacting working groups centered on panel and
plenary discussions. The extensive minutes generated
during the discussions formed the basis for the present
report, which is organized into four sections following
the objectives set for the three dedicated panel
presentations at the workshop. The underlying
message was clear there is reason for genuine
concern, although the details are not fully resolved.
The official products from this effort are embodied in
resolutions endorsed by the workshop participants.
These are presented at the end of each chapter in this
report.
The meeting concluded with a commitment to
persevere in engaging the broad community of federal
and state air and water regulators in discuss and
potentially act on this shared resources issue. The
group also committed to continue convening
approximately every 18 months. Additional meetings
with related purposes are now in the planning stage.
All possible steps will be taken to coordinate these
meetings so that a coherent program to assess and
solve the broad environmental problems of the nation's
coastal resources can be assembled with the least
possible delay.
TABLE OF CONTENTS
1. INTRODUCTION
2. THE EVOLVING SCIENCE
2.1 Issue: New and Expanded Approaches for Persistent Questions
2.2 Discussion: Areas of Uncertainty.
2.3 Addressing the Issue: Find Common Ground
1. INTRODUCTION
An analysis by scientists at the Environmental Defense Fund
(EDF) in 1988 on the role of acid rain in coastal water
pollution alerted the scientific community and the public to
the likelihood that atmospheric deposition can contribute
significantly to the declining health of coastal ecosystems
(Fisher et al., 1988; Fisher and Oppenheimer, 1991). The
news was met with cynicism, because the research
community had long operated on the assumption that the
causes for over-enrichment were entirely related to
discharges of nitrogenous chemicals from the land and from
point sources into rivers and streams. However, subsequent
analyses repeatedly confirmed that a significant fraction (20-30%) of the nitrogen entering the Chesapeake Bay is derived
as a result of atmospheric transport from distant as well as local sources (e.g. Linker et al., 1996; Valigura et al., 1996).
Table 1 lists a number of estimates (as of 1995) derived from either peer-reviewed literature or advocated by a major
management organization (e.g., an EPA National Estuary Program) for the Chesapeake Bay and several other coastal
and esturaine water bodies. Two-thirds of these analyses suggest air contributions of 20% or higher, not far from the
original EDF projections. There are several caveats related to Table 1 (see Valigura et al., 1996). The strongest of
these is that agreement in numbers across the Table should not be taken as evidence supporting the quantifications
themselves, since it may reflect the fact that overall understanding of how atmospheric deposition enters the aquatic
biosphere has not expanded greatly in the past decade.
In the early 1990s, several major developments spurred interest in the issue of atmospheric input to waterbodies. The
1990 amendments to the Clean Air Act Amendments mandated the establishment of the "Great Waters" Program,
which requires EPA to work with NOAA to evaluate the extent of atmospheric deposition of hazardous air pollutants
(and in the discretion of the Administrator, other air pollutants) to the Great lakes, the Chesapeake Bay, Lake
Champlain and coastal waters..." The overall goal of the Great Waters Program has been to identify and prevent
adverse effects due to air pollutants deposited to aquatic ecosystems. In 1991, the Coastal Ocean Program of the
National Oceanic and Atmospheric Administration (NOAA) initiated a short-term, but productive, examination of the
issue (ANICA -- the Atmospheric Nutrient Input to Coastal Areas program; see Valigura et al., 1996). In 1993, the
Chesapeake Bay Program formed an Air Quality Coordination Group (AQCG) to focus efforts on refining estimates
of the atmospheric contribution to well-recognized declines in Bay fisheries and water quality. The AQCG and the
leaders of the ANICA program joined forces in September 1994 to conduct a workshop on reducing the uncertainties
in estimates of atmospheric deposition loadings received by the Chesapeake Bay (the "Mount Washington Workshop",
Baltimore; Hicks et al., 1997). Participants at this workshop identified six areas where attention should be directed.
Since this workshop, it has been a major focus of the AQCG to work towards implementation of these
recommendations (see discussion below, in Section 2.1).
In 1995, the Chesapeake Bay Program sponsored a coastal shared resources workshop titles, "Airsheds and Watersheds:
The Role of Atmospheric Nitrogen Deposition". This workshop was conducted at the Airlie House in Warrenton,
Virginia (the "Airlie Workshop"). The main goal of the workshop was to alert coastal ecosystem scientists and
managers to the need to work together to reduce a common threat due to atmospheric deposition. This marked a major
step forward, since the workshop targeted several distinct issues that had become apparent as stumbling blocks:
changes in air quality affect many downwind areas, and so affected communities should work together to assess
the benefits of changes in deposition from the air, and
water quality and air quality regulators and scientists need to join together to derive an understanding of how best to manage and protect the coastal aquatic ecosystems.
Table 1. Select estimates of nitrogen loading (millions of kg) to selected coastal waters attributed to direct and indirect atmospheric input (as of 1995).
| Surface area watershed (km2) | Surface area of tidal waters (km2) | Deposition onto the watershed | Deposition onto the tidal waters (i.e., direct load) | Atm. load delivered from the watershed (i.e, indirect load) | Total atm. Load | Total load from all sources (incl. Atm.) | % load from the atm. | Ref. | |
| Narragansett Bay (R.I.) | 4708 | 328 | 4.2 | .3 | .3 | .6 | 5 | 12 | 1 |
| Delaware Bay | 36905 | 1846 | 53 | 3 | 5 | 8 | 54 | 15 | 2 |
| Long Island Sound | 43481 | 4820 | 45 | 5 | 7 | 12 | 60 | 20 | 3 |
| Albemarle-Pamlico Sounds | 59197 | 7754 | 39 | 3 | 6 | 9 | 23 | 38 | 4 |
| Chesapeake Bay | 165886 | 11400 | 175 | 16 | 29 | 45 | 170 | 27 | 5 |
| New York Bight | 50107 | 38900 | 69 | 54 | 8 | 62 | 164 | 38 | 1 |
| Rhode River (Md.) | 33 | 4.9 | - | .005 | - | .005 | .012 | 40 | 6 |
| Waquoit Bay (Ma.) | 70 | 8 | .062 | - | .0065 | .0065 | .022 | 29 | 7 |
| Flanders Bay (N.Y.) | 83 | 39 | - | .027 | - | .027 | .36 | 7 | 8 |
| Delaware Inland Bays | 800 | 83 | - | .28 | - | .28 | 1.3 | 21 | 9 |
| Sarasota Bay (Fl.) | 524 | 135 | - | .16 | - | .16 | .6 | 26 | 10 |
| Patuxent River (Md.) | 2393 | 137 | - | .22 | - | .22 | 12.6 | 13 | 11 |
| Newport River Coastal Waters (N.C.) | 340 | 225 -1600 | - | .095-.68 | - | .095-.68 | .27-.85 | 35-80 | 4 |
| Narragansett Bay (R.I.) | 4708 | 328 | - | .4 | - | .4 | 9 | 4 | 12 |
| Choptank River (Md.) | 1779 | 361 | - | .57 | - | .57 | 1.54 | 37 | 11 |
| Guadalupe Estuary (Tx.) | - | 551 | - | .31 | - | .31 | 4.2-15.9 | 2-8 | 13 |
| Potomac River (Md.) | 29940 | 1210 | - | 1.9 | - | 1.9 | 35.5 | 5 | 11 |
| Tampa Bay (Fl.) | 6216 | 1031 | - | 1.1 | - | 1.1 | 3.8 | 28 | 14 |
| Massachusetts Bays | - | 3700 | - | 1.6-6 | - | 1.6-6 | 22-30 | 5-27 | 15 |
1. Hinga et al., 1991; 2. Scudlark and Church, 1993; 3. Long Island Sound Study, 1996; 4.Paerl and Fogel, 1994; 5. Linker et al., 1993; 6. Correll and Ford, 1982; 7. Valiela et al., 1996; 8. Peconic Bay NEP; 9. Delaware Bays NEP; 10. Sarasota Bay NEP, 1995; 11. Boynton et al., 1995; 12. Nixon et al., 1995; 13. Brock et al., 1995; 14. Tampa Bay NEP, Zarbock et al., 1994; 15. Massachusetts Bays NEP, 1996.
Furthermore, it was recognized that several uncertainties still need to be addressed -- the ability to measure or
otherwise quantify dry deposition of nitrogen, the amount of the nitrogen deposited to land that is transmitted through
watersheds to coastal ecosystems, and the role of ammonia and organic nitrogen.
The Airlie Workshop report (AQCG, 1995) was well received, and served as a vehicle to move into the second Airsheds
and Watersheds workshop held in Raleigh, North Carolina in March, 1997. The report that follows is a summary of
the presentations, deliberations, and conclusions of this second workshop. The specific goal was to re-invigorate the
issue of air deposition and related loadings as contributions to coastal ecosystem decline. The meeting was designed
as a sequential series of interacting working groups centered on panel and plenary discussions (note agenda in
Appendix 1). The extensive minutes recorded by rapporteurs allowed the following report to be produced. Discussions
from the meeting were extracted from the notes and organized into four sections which follow the objectives set for
the three dedicated panel presentations at the workshop. The products from this effort are embodied in resolutions
endorsed by the workshop participants. These are presented at the end of each chapter.
2.1 Issue: New And Expanded Approaches For Persistent Questions
Many of the questions addressed at the Airlie Workshop were, by necessity, carried forward to the Raleigh Workshop.
Additionally, a list of research priorities, developed at the Mt. Washington Workshop (Hicks et al., 1997) and
subsequently endorsed at the Airlie gathering, was also carried forward to the Raleigh workshop.
There will always be some level of uncertainty associated with assessments of the kind addressed here; the key is to
recognize this and define what level of uncertainty is tolerable. The Airlie Workshop participants noted that current
assessments are almost entirely based on large-grid model outputs, which are supported by a meager amount of actual
data. Nevertheless, one of the conclusions reached at the Airlie Workshop was that scientific uncertainties have been
reduced to the extent that some new or modified regulations or controls can be justifiably implemented. Subsequently,
the following research priorities, developed during the Mt. Washington Workshop, were fully endorsed.
(1) The top research priority remains the need to establish integrated monitoring stations to provide high quality
deposition and watershed retention data within the catchment area. Preferably, several research sites should be
set-up where actual deposition measurements can be made at locations where supporting ecological data are also
collected. This need parallels contemporary efforts (see CENR. 1997) to construct a national environmental
monitoring framework that adds ongoing research to a subset of routine monitoring locations, in order to provide
an anticipatory component to monitoring studies..
The other priorities reflect the current state of science, and the relative importance of different areas of uncertainty.
(2) The second priority calls for taking spatial irregularities into account in atmospheric deposition models. This
relates to the need to improve atmospheric transport and deposition models.
(3) The third priority is a call to improve biogeochemical watershed models, especially from the perspective of internal
cycling and retention of deposited materials. As in priority two, this priority relates to improving models, but in
regard to their ability to describe the retention and transport of deposited chemicals in watersheds.
(4) The fourth priority calls for refining emissions inventories and projections on which scenario investigations are
based. In essence, there is need for better spatial and temporal detail in emissions inventories.
(5) The fifth priority is a need to enhance all ongoing data collection efforts, especially those related to specific process
studies. This primarily relates to the need for intensive studies of the meteorology and atmospheric chemistry in
coastal regions.
(6) The sixth priority calls for the construction of an extensive array of relatively simple measurement sites to provide improved spatial detail. This activity will support the integrated monitoring activity listed as priority one.
There is an broad need to develop field techniques for direct measurement of
various nitrogen compounds continuously, with both rapid response and high
precision. Such techniques would allow us to determine fluxes and deposition
velocities of these compounds, which are critical model inputs. We cannot judge the
extent of estimation and other errors in current model projections because these
benchmarking measurements do not exist. The top three research priorities reflect
the general recognition that current models may be misleading.
2.2 Discussion: Areas of Uncertainty
Workshop participants acknowledged and built upon the conclusions reached in the
previous two workshops. However, extended discussion resulted in a few new
research priorities being added to the list.
Natural Sources of Nutrients. Anthropogenic sources of nitrogen to the atmosphere
are well recognized and continue to be better characterized. This is not the case for
natural sources such as N-fixation and losses from denitrification. Lack of quantification of denitrification could cause
overestimation of nitrogen flux to water bodies. Another consideration that is not well understood is the facilitating
role of iron and of nutrients other than nitrogen in the biological assimilation of large increases in nitrogen-nutrient
inputs. Approximately five times more nitrogen-nutrients are reaching the North Atlantic Ocean than in pre-industrial
times (Duce et al., 1991; Howarth et al., 1996). Because rain contains iron and other nutrients as well as nitrogen,
atmospheric deposition of inorganic nitrogen is a more potent stimulant of biological production in coastal and marine
environments than other sources of dissolved organic nitrogen (DIN). This has been demonstrated for the Sargasso
Sea near Bermuda, where rainfall has been shown to stimulate algal growth more than if nitrogen-nutrients alone were
added (Paerl, 1997).
N Speciation. The primary questions raised by the workshop participants were: What are the natural sources of N,
how much nitrogen existed before modern times, and what form was the nitrogen in? Answers to these and similar
questions are required before it can be determined with confidence if new regulations are needed. The nitrogen
compounds of main relevance in the context of nutrient loadings generally fall into three categories or species groups:
nitrate (NO3-), ammonia/ammonium (NH3/NH4+), and organic nitrogen (Norg). Along the east coast there have been
documented changes in the relative ratios of these components in precipitation. For example, in North Carolina this
change has been linked to increased emissions from expanding agricultural activities and animal farming, and to
changes in land use patterns. The record from a site near Clinton, North Carolina, of the National Atmospheric
Deposition Program (NADP) reveals a tripling of NH4+ concentration in rainfall since 1977 (Paerl, 1997). This is
substantially more than the increase in NO3- concentrations during the same time period. There is cause for concern
because NH4+ is the most reactive form of nitrogen. At this time, NH4+ and Norg are not regulated at all. Norg (only
recently investigated in rain) is an issue because the nitrogen in rainfall can be dominated by organic species (up to
80%), yet it is unknown how much of this Norg is biodegradable or can be used biologically by algae and bacteria
(Cornell et al., 1995; Peierls et al., 1997).
Variability. All environmental systems are subject to natural variability, largely independent of human influence.
Natural variations in watershed fluxes of nutrients to marine ecosystems present two challenges in managing nutrient
reductions from human sources.
First, there is the challenge of collecting sufficient long- term monitoring data to demonstrate the effects of
management actions on riverine nutrient fluxes. This requires multi- year monitoring data with adequate coverage
of seasonal periods and episodic events. In the Chesapeake Bay region, for example, some limited progress has been
made towards achieving nutrient reduction goals. Extensive fall-line monitoring data collected for major Ba y
tributaries over the past decade show that total nitrogen concentrations have declined by 10 to 30 percent at five of nine
major tributaries, with the remaining tributaries showing no change (L. Darrell, U.S. Geological Survey, written
comm., 1997). In tributaries of other regions where less frequent monitoring data are collected, more than 10 years
of data are likely to be required to detect the effects of reduction strategies. Current flux estimation methods can assist
efforts to determine the monitoring requirements for detecting future changes in stream nutrient fluxes.
Second, there is the question of whether the ecosystem benefits of nutrient reductions can be achieved and sustained
recognizing that, even as progress is
made towards nutrient reduction goals
in terms of lowering mean flux,
year-to-year variations in flux, and
infrequent episodic events (e.g.,
100-year floods), may limit the
effectiveness of management actions in
improving ecosystem health.
Resolution of this question hinges on
quantification of the magnitude of
natural flux variations and an improved
understanding of the effects of these
variations on ecosystems. A recent
study of nitrate flux in tributaries to
major U.S. estuaries (Alexander and
others, 1996) addresses this first need,
and indicates that year-to-year
variations typically range from 20 to
40% of the long-term mean flux. For
nearly one half of the rivers studied,
these variations correspond to a 10 to
35% annual probability of exceeding the
long-term flux by a magnitude roughly
equivalent to nutrient reduction goals adopted for the Chesapeake Bay (i.e., 40%). For major Chesapeake Bay
tributaries, the annual probabilities are less than 20%. Our understanding of the effects of large, infrequent events and
future climatically-induced changes (i.e., global climate change) on nitrogen flux is less certain, however, because of
the poor availability of monitoring data for high stream flows. The limited number of case studies of extreme events,
including those of Tropical Storm Agnes in 1972 and high flows on the Mississippi River in 1993, will continue to be
primary sources of information for predicting the future response of coastal ecosystems to large natural variations in
streamflow.
Biological Response. The nitrogen delivered to ecosystems by atmospheric deposition is indisputably biologically
active, yet its distributed biological consequences are often masked by the stronger and more local effects of point
source loadings. For example, in Sarasota Bay, Florida inorganic nitrogen deposition loads have doubled yet the Bay
is reportedly getting cleaner (the area of sea grasses has increase by 640 acres between 1988 and 1995). This appears
to be because sea grasses are growing in areas that benefit directly from clean-up efforts; $1 million has already been
spent, with an additional $2 million still to be invested on improving wastewater treatment systems. Similar
improvements are found elsewhere in the Bay, due to decreases in loadings from other point sources. This raises a
crucial management question: To what extent will the measurable biological benefits track reductions in
nitrogen/phosphorus loading from the air?
Seasonality. Seasonality of deposition has been shown to be an important consideration in assessing growth rates of
aquatic vegetation in North Carolina, but not all areas are sensitive to the time of the year when the inflows occur.
This is an important question from a management point of view. In particular, most debates at this time are concerned
with the extent of seasonal reductions needed to improve ground-level ozone concentrations around the country. The
ozone regulatory community notes that ozone exceedances occur mainly in the summer, and thus favors imposing
more stringent estrictions on emissions of ozone precursors (including NOx) in the summer months only. On the other
hand, the delivery of atmospheric nitrogen-nutrients to sensitive ecosystems is a year-round phenomenon. Ozone-centered discussions exclude any consideration of annual controls for additional water quality benefits from changes
in NOx emission regulations.
2.3 Addressing the Issues: Finding Common Ground
Integrate Monitoring Sites.
As previously discussed, the highest scientific priority identified at the Mount
Washington Workshop (Hicks et al., 1997) is to establish integrated monitoring sites, where different scientific
specialists could target their research attention so as to learn how to coordinate across the various disciplinary
boundaries. Subsequently, at the federal level this has become a high priority for the Committee on Environment and
Natural Resources, National Science and Technology Council. A "National Environmental Monitoring Framework"
has been developed (CENR, 1996, 1997), which envisions a nested network approach, with the most intense
monitoring activities at a series of "index sites". The premise is essentially to expand monitoring of environmental
indicators by adding a research component to pinpoint the environmental stressors that are responsible for changes that
are detected in the conventional monitoring programs. Long-term monitoring of stressors and ecosystem health
provides for 1) status and trends and issue/problem identification (an early warning system), 2) an input to research,
model evaluation, and risk assessment, and 3) a measurement of the effectiveness of management decisions. This is
precisely what is needed to address the multi-media coastal ecosystem decline problem, in which all of the air, land,
and water are affected and are interacting.
The Raleigh participants agreed that there continues
to be a need to establish more coordinated cross-media monitoring, incorporating air and water
sampling at locations where ecosystem monitoring is
already underway. A multi-organizational approach
is recommended, to draw on the relevant scientific
skills developed in the separate agency programs and
to increase the chances of long term funding.
Sampling protocols should be comparable, without
being rigidly standardized to a degree that might
constrain the advancement of the science or limit the
precision of the data obtained. It is possible that
institutional hesitancy will inhibit adoption of the
cooperative and coordinated approaches that the
scientists have long advocated because sponsors may
be wary of threats to their individual control and
autonomy. It was agreed that the dangers of not
adopting this approach outweigh any agency
chauvinism that might be an obstacle.
The question arises as to the role of State environmental agencies in the development of these cooperative monitoring programs. This might be a difficult issue to address, because there is often little coordination among programs within a state. Participants felt it would be important to take some first steps that could be accomplished smoothly and to avoid potential obstacles. As a beginning, it was suggested that the community could build upon the existence of NOAA's National Estuarine Research Reserve System (NERRS) of which there are currently 17 sites on the east and gulf coasts and the EPA's National Estuary Program (NEP) of which there are presently 20 sites on the east and gulf coasts. There is a steady increase in the number of cooperative efforts among these sites in the past, a tacit recognition of the opportunity and need to construct a new and more advanced infrastructure. It has yet to be determined, which (if any) of these sites are located in areas where measurements of wet and especially dry deposition are feasible.
(Figure 4 - this is a full page picture of the NEP and NERRS sites)
Assess Atmospheric Inputs to Coastal Areas. At the Raleigh Workshop, expert's views on the essential elements of an assessment of atmospheric input to coastal areas were sought (in order to compare waterbody to waterbody). It was emphasized that there are two different kinds of assessments currently in popular demand. The first is an assessment of the state of the science, which essentially develops blueprints for future research programs. The second is an integrated assessment, which is directed to guiding management decisions and optimizing costs and benefits. The discussion at the Raleigh Workshop focused entirely on the second kind of assessment, integrated assessment in support of policy and setting environmental regulations. Nevertheless, there were several implications identified regarding needs for additional information: quantifying anthropogenic sources may prove difficult; increased monitoring of fluxes may be required; and biological significance of variations may need to be explicitly incorporated.
Experts agree there are three principles that make a successful integrated assessment:
The main focus should be on the linkages between different processes along the conceptual pathway from
emissions to loadings to effects to benefits, rather than on the individual processes themselves.
"Integrated monitoring" yields the key understanding that is required. The key characteristics of integrated
monitoring are collocated studies of all of the media (terrestrial, aquatic, and atmospheric), an ongoing research
activity to bring the contributing disciplines together, and a coupling with several of the ongoing routine
monitoring networks that are currently in place. Integrated monitoring is intended to add an anticipatory element
to current status and trends monitoring programs. In the lack of accurate and/or adequate information, great care
must be taken. There are two potentially competing admonitions that are relevant: it is better to give conflicting
information than no information, and no data are often better than bad data alone.
Assessments evolve as understanding improves; hence, the next assessment can best be planned while the current
assessment is underway.
In a multi-agency or multi-state operation, it is difficult to conduct an integrated assessment because of the continual
need to satisfy all parties and form working and lasting agreements on central issues. However, the alternative
(focusing on a state-of-the-science assessment) does not usually provide the information required by decision makers.
Simply reporting scientific knowledge without summarizing its relevance and meaning does not guarantee its use in
addressing the true concerns of society or in serving public welfare. In addition to depending on science and
understanding, a successful integrated assessment depends upon communication: communication among the scientists,
communication between scientists and policy makers, and communication with the public and other constituencies.
2.4 Resolutions
The group reached a general consensus that nutrient loadings to many estuarine and coastal ecosystems are excessive,
and that a part of this loading is associated with atmospheric deposition. The proportion attributable to the atmosphere
is site-specific and can vary widely (from a very small contribution in some cases to a significant factor in others). The
following resolutions were discussed and accepted:
The deposition data bases which quantify atmospheric N-species deposition to both water and land surfaces
should be refined and made more widely available. These data bases should be used to evaluate the accuracy
of the models describing atmospheric transport and deposition (to land and to water). (97% agreed)
To further understand the anthropogenic (and hence controllable) atmospheric contribution, the deposition (and
loadings resulting from this deposition) of non-Clean Air Act nitrogen species such as ammonia and organic
nitrogen should be quantified. (95% agreed)
Better quantification is required of the amount of atmospheric N-species loading resulting from deposition onto
a watershed with subsequent transport to the receiving waters (i.e. the indirect load) as well as better
quantification of the direct load. (95% agreed)
Data are needed to quantify the biological effects caused by direct atmospheric deposition to the water surface.
(87% agreed)
The majority of participants disagreed with the following related proposal:
In the near term, primary emphasis should be placed on direct deposition/load onto the surface of our coastal
waters and estuaries. The uncertainties surrounding the amount of atmospheric nitrogen load resulting from
deposition to a watershed with subsequent transport to the receiving waters (i.e. the indirect load) are so great
that it should not be considered in the decision making process for at least another 5 years. (73% disagreed)
It was emphasized in the discussion that it is critically important to maintain the nation's deposition monitoring
programs. The participants agreed that
Noting the vulnerability of these programs and networks to interruption through actions of single agencies, it is
recommended that immediate steps be taken to protect critical ongoing monitoring activities. (93% agreed)
However, participants were divided on the need for a formal mechanism to ensure monitoring continuity. Nevertheless,
the majority of the participants agreed with the recommendation that
A memorandum of understanding (or some other instrument) be put into place to require at least three years
notice in the event of any agency action that might jeopardize the ongoing measurement program. (75% agreed)
3.1 Issue: Conceptually Adequate Cost-effectiveness Estimates
A primary goal of environmental policy economic analysis is to quantify the relationship between different levels and
types of public investment in pollution control (costs) against actual or projected reductions in pollutant levels
(effectiveness or benefits). Such analysis can be performed retrospectively to assess the effectiveness of controls or
practices implemented and to compare actual costs incurred against the estimated costs originally used in planning or
options analysis. It is used prospectively to evaluate the relative merits of different control options. Failure to account
for all significant costs in a prospective economic analysis may lead to selection of an option that can be implemented
only partially, or not at all, given available resources. The "costs of doing nothing" are an accounting of projected costs
that would have been saved by not imposing any additional controls against the pollutant levels or environmental
damages that would have occurred. "Costs of doing nothing" can be quantified either retrospectively or prospectively,
and a first-order question always relates to the costs of doing nothing compared to the costs of other options.
3.2 Discussion: Economic Analyses to Date
Nitrogen-nutrient modeling in its current early state of development suggests that agricultural best management
practices (BMPs) are the most cost effective means to achieve desired nutrient reductions. However, knowledge of the
BMPs' underlying cost-effectiveness estimates is quite poor. But the relevant issue for this workshop, with its emphasis
on the delivery and role of air pollutants, is not whether we need to examine the relative cost effectiveness of air
reductions versus BMPs or other strategies. Air alternatives should be incorporated into a comprehensive program of
nitrogen loading control. Once the gains to the environment in other areas (e.g. ground-level ozone) are recognized
and quantified, the apportioned cost of airborne NOx control may be reduced.
There are three major questions that must be addressed as the airshed-watershed connection is considered within the
current modeling framework:
(i) How valid are the cost and effectiveness estimates -
urban and agricultural BMP as well as atmospheric?
(ii) Do we have a modeling strategy for improving cost
effectiveness information?
(iii) Is there too much reliance on modeling as a guide to
policy?
Is There A Conceptually Adequate Framework for
Cost-Benefit Analysis? To assess the validity of the cost
information now being used, it is useful to first describe,
at a conceptual level, the costs that will be incurred in
implementing steps to reduce nitrogen loads. These
include:
outlays for equipment, labor and materials to change
production or consumption practices, initially
for capital investment and then for annual
operation and maintenance.
effects on business profits (for example, the cost to a farmer to implement a best management practice like a forest buffer strip includes not only installation and maintenance costs but also includes forgone revenues from taking that land out of production, or the cost to an electric utility that is required to install controls of questionable environmental benefit that cause the plant to become noncompetitive.)
legal and administrative costs the source incurs to assure it is in compliance with a regulation or financial incentive
program, and
costs borne by government agencies (above and beyond cost-sharing subsidies and revenue losses from offering tax
advantages to administer nitrogen reduction programs (information gathering costs, technical analysis costs,
technical assistance costs, costs to negotiate agreements and administer permits, program enforcement, costs
for monitoring, conviction of violators and penalty assessment).
Economic analyses to date have demonstrated how useful cost and effectiveness estimates are in policy studies even
when the estimates are uncertain. Concerns about the impact of these uncertainties in economic projections have
usually been well expressed in the integrated assessment documentation, but they have often not been fully appreciated.
To have data on all the conceptually necessary cost categories and to have effectiveness data for all the applicable
practices is a tall order, considering that most studies have short time schedules and limited financial resources to
produce a report.
Cost Overestimation.
Cost overestimation has proven to be the rule rather than the exception. As a recent example,
it is widely recognized that costs to reduce sulfur emissions for acid rain were overestimated. In this particular case,
cost overestimation was due primarily to mis-information in modeling and changes in technology. Marketplace
competition and creativity, and the availability of low sulfur coal are the specific reasons most often cited. Another
example of innovation is related to the Toxic Release Inventory (TRI), which has had major impact on pollution
prevention. In this case, industry came up with many innovative ways to comply with the new emission regulations,
at much lower costs than had been anticipated in the formal assessments conducted previously. As a generalization,
it seems that the real costs of doing the right thing must be expected to be lower than the estimated costs.
It is important to recognize that control strategies can have different phases. The costs and benefits for each phase may
not be the same. Initially, there might be low cost and high benefit, but as controls become more stringent costs can
rise rapidly. A plot of costs versus benefits is generally a curve; linearizing it will cause grave errors in interpretation.
There is current debate about whether it might be preferable to focus not on cost (the financial burden imposed on the
public) but on value (the benefits derived from the expenditure per unit of cost).
Making Economic Analysis Relevant to Stakeholders.
The question of central interest to most stakeholders relates
to the personal impact of proposed regulations. In this regard, economic analyses are often misused. There will
certainly be water quality benefits accruing as a direct consequence of air emissions reductions, but at present the
association is imperfectly known. In any event, society will bear the costs of the air emission reductions, just as society
will benefit from any water quality improvements that then follow.
As time progresses, it is anticipated that there will be increasing benefit from constructing market-based regulatory
mechanisms. Some major questions remain to be answered can market based mechanisms be enforceable? And how
can costs and benefits be anticipated with greater accuracy than in current integrated assessments? The dollar values
associated with costs, benefits, and values need to have accuracy and validity.
3.3 Addressing the Issues: Plan and Perform the Analyses
From a water perspective, as we move from technology based effluent standards to ambient water quality goals under
an expanded Total Maximum Daily Load (TMDL) process, the question is - how much clean up is enough? This
question is not likely to be answered by formalistic cost-benefit tests. Rather a public consensus is needed, built around
an incremental assessment of physical, chemical and living resource outcomes for each additional increment of cost
to achieve water quality improvement. The key deciding factor is usually to stop imposing additional controls when
the marginal cost curve starts rising rapidly the term used is to adopt a "knee of the curve" analysis.
Keys to Successful Cost Effectiveness Analyses.
Costs are increasingly important. Improved accuracy in cost
estimation will ensure that public funds are wisely spent and that regulators are not surprised by opposition when costs
are especially onerous on some sectors of the community. Yet, existing cost analysis capabilities are weak. The
suggestion was made that a six-step strategic approach to improved cost effectiveness analysis be adopted (see sidebar).
A lesson learned from economic analyses conducted so far is not only that poor assessments result when a minimal
effort is invested in cost estimation, but also that the quality of the overall assessments is continually threatened by the
failure to institutionalize the cost effectiveness analysis process. Skills that are learned today should be permitted to
become the skeleton on which better products can be constructed tomorrow.
Understand the Limitations of Modeling.
The most
accurate cost effectiveness analyses are conducted with
models at very small spatial scales, such that differences
in factors such as soils, hydrology, crops, population
density, etc., can be taken into account. Problems arise
when the questions asked address larger scales,
requiring a scaling up of assumptions. It follows that
models may help with general assessments of trends and
policy screenings but will not predict accurate
implementation costs on landscape scales.
Even as better models of existing regulatory systems are being built, there are changes being made in the basic regulatory institutions. For example, there are ongoing efforts to create incentive-based regulatory institutions like discharge allowance trading systems that will lie outside the structures and assumptions of any existing model. These institutions are designed to permit flexibility in seeking out cost savings in making load reductions and to offer incentives for that performance. Human creativity will discover process adjustments, production management and new technologies that cannot be anticipated by modelers. The necessary consequence is that the state of regulatory institutions represented by regulatory models always lags behind regulatory reality. As a corollary, if regulations are designed for their incentive effects, available models will predict the worst case, not the best case, for costs and environmental results. The evidence for this conclusion is strong.
Being able to measure, monitor and enforce change in
nitrogen discharges is a requirement of the innovative
regulatory systems that are now being developed. New
institutions for trading nitrogen loads will demand
different public costs for certification of performance,
monitoring and compliance assurance and perhaps
higher public sector costs. But the overall savings may
be significant.
3.4 Resolutions
Workshop participants noted the need for support of programs specifically designed to analyze the costs and benefits
of reducing air deposition to coastal areas, as well as the benefits to coastal areas derived from implementing the Clean
Air Act. Some participants took the view that the scientific issues should be addressed first and related questions
answered before diverting scarce available resources to economic considerations. However, most participants held the
view that economic studies should parallel scientific efforts, providing a balanced program. Most of the participants
agreed that
Although initial economic studies have been conducted, it is necessary to devote substantial research funds
to the economic evaluation of air deposition, including luxury benefits, over-estimated costs, and costs
relative to other sources. (70% approval)
4. COMMUNICATING WITH THE PUBLIC AND ELECTED OFFICIALS
4.1 Issue: Developing The Big Picture
Talking to the Public. Public perception is that water pollution comes from the end of a pipe that can be seen. This perception must change, so that public acceptance of broad-based and cost-effective environmental protection can be garnered. The ongoing debate about the enhanced vehicle inspection and maintenance program serves as an example of how incorrect public perceptions can impede the integrated regulatory progress. Under the new inspection program, owners must have their automobiles inspected using a dynamometer system that requires more time and involves drivers relinquishing control of their vehicles for the duration of the test. Public reluctance to accept this program
is aggravated by fear of an additional charge levied for the more advanced tests. The test program is widely seen as
onerous, even though the results are of great benefit in detecting poor vehicle performance. This example highlights
that there is no clear evidence that the public views itself responsible for emissions reductions to improve air quality.
On the other hand, the issue of declining water quality seems to have the attention of the public. Increased public
awareness about coupled air and water issues needs to be fostered.
Who pays and who is at fault are genuine issues; there continues to be difficulty in convincing people that they
themselves are part of the problem. There are overtones of suspicion that innocent parties will finish up bearing the
cost of remediation, and that guilty parties will not only go free but will somehow continue to pollute. There is great
uncertainty about the public perception of some of the regulatory institutions now being postulated; the degree of public
comfort with new proposals needs to be explored. To assist in the process, model predictions are needed. If these
predictions are later proved wrong, then there may be an unwelcome backlash. Models are useful, but there are
problems with how their results are communicated. For example, how can model uncertainties be made clear without
destroying public confidence and without confusing the policy-setting process?
Talking to a Public Official. The nation's environmental protection machinery is under increasing public scrutiny,
and it is hard to convince a political official to fight (and spend today's scarce money) for something when the benefits
may not be seen for ten years, often well after their term in office expires. The story needs to be very convincing.
Public officials are stewards of today's
and tomorrow's environment, but
today's voters need to be assured that
their moneys are well spent. Therefore,
it is important to translate potential
long-term environmental benefits into
terms that today's voters can understand
and support. People often want to know
how they will benefit in their lifetime.
It is troubling when the answer involves
model predictions, because the
provision of numbers implies an
accuracy that is rarely warranted.
Provision of Compelling Information.
It is frequently stated that there is no
absolute proof that atmospheric
deposition affects aquatic ecosystems, and so discussion of integrated air/water regulatory approaches is premature.
It is true that understanding of the linkages between atmospheric deposition and quantifiable ecosystem consequences
is presently incomplete. It is equally true that there is an overwhelming desire to document the biological consequences
of atmospheric deposition, especially the biological benefits of reductions in it. As of yet, there is no direct proof that
if atmospheric emissions of nitrogen oxides were decreased there would be an improvement in aquatic living resources.
Managers need to be able to say with some certainty that emissions of a specific chemical are causing a particular
adverse impact, so that decreases in such emissions will
have obvious positive consequences. The "Shared
Resource" message that there are multiple benefits to
reducing air pollution (as well as multiple impacts if air
pollution is not reduced) needs to be impressed upon
policy makers. There is also a need to impress upon
policy makers the need to identify nitrogen (and other
nutrient) issues unique to individual waterbodies.
Effects of Air and Other Non-point Source Reductions.
At this time in the U.S., there is no direct comparison
available showing the relative biological significance of
nitrogen coming through the atmospheric pathway versus
other non-point sources. There is data available in
Europe, however, that indicates coastal regions there are
stressed by atmospheric deposition. These data also
indicate that, though inland water bodies are affected by
nitrogen nutrients from various sources, atmospheric
input is the dominant source to some waterbodies,
particularly in the Netherlands. It is hoped that the
coastal eutrophication problems of the eastern U.S. will
be addressed in a manner more effective than has been
the case elsewhere. For the eastern U.S. the timing is
urgent since population pressures continue to grow.
Lack of Clarity Regarding Specific Legal Constraints.
The Clean Air Act Amendments of 1990 are largely
targeted toward protecting human health. It remains to
be seen how much the air statutes can be used to generate reductions/benefits to other media. Section 112 of the Clean
Air Act (CAA) provides the legislative basis for regulations concerning emissions and deposition of hazardous air
pollutants. In response to increasing evidence that air pollution contributes to water pollution, Congress included
section 112(m) in the 1990 CAA Amendments to address atmospheric deposition to the Great Lakes and Coastal
Waters. Nitrogen compounds have subsequently been added to the list of pollutants of concern in the Great Waters
(e.g., Chesapeake Bay, Tampa Bay, etc.). While there is a provision to take air-related action for adverse
environmental impact, to date, conclusive linking of specific adverse biological effects to atmospheric deposition has
been difficult to establish. Currently no statute has been written to provide an agency with non-discretionary duty to
addressing nitrogen loadings. EPA is addressing excess nitrogen loadings to estuarine and coastal waters as
concomitant benefits using provisions under Titles I, II, and IV for controlling NOx emissions from stationary and
mobile sources.
There are many environmentally relevant effects of atmospheric nitrogen compounds. For a true multi-media, or multi-source attack on water pollution and aquatic environmental effects that includes air, we need to find a way to work
creatively within the constraints of existing statutes.
4.3 Addressing the Issues: Integration Between Air and Water Management
The national environmental regulatory process has begun to consider estuarine impacts for both nitrogen and toxic
compounds. Some initial steps have been taken to coordinate technical standards and to unify analyses of regulatory
impacts across the board. There are also efforts to determine the estuarine benefits of the new proposed ozone and
particulate matter standards. There is a significant movement to consider water quality impacts along with human
health. The role of the States in this regard is quite important, because state-level oversight on both these issues is
critical.
Investigate Common Linkages.
One potential linkage
across federal entities is to fully implement the
Government Performance and Results Act (GPRA)
which applies to every Federal agency. GPRA appears
to offer an effective way for each agency to link
administrative actions and environmental indicators.
The GPRA requires every federal agency to have specific
results for actions taken. For example, EPA's Water
Program is making GPRA objectives the same as
milestones to achieve national environmental goals. If
this effort is successful, it could create a common
interagency vocabulary.
Another path is to look at environmental indicators for strategic planning purposes, i.e. to design and use indicators
to develop long-range planning and to link these with day-to-day management decisions. Systems of this kind would
provide useful opportunities to bridge gaps between science and policy.
Present Options to Policy Makers.
There is increasing recognition of the benefits of incentive-based regulations.
These have proved very successful when applied to water quality problems, but there has been less exploration of them
in the context of air regulations. Market-based programs have shown that environmental benefit can happen as part
of cost sharing efforts. In some cases, the benefits will be seen by communities other than the ones who take the action.
This is especially the case for air regulations, for which benefits of emission reductions are often most detectable
downwind. Such considerations need to be fully quantified because at the time of the workshop these benefits were
taken as "luxury benefits" from the water program's point of view.
Secure Funds for Research.
The need to couple air and water issues generated discussion of the need for funding to
support cross-media programs dealing with integrated air/water (airsheds-watersheds) studies. The primary historic
obstacle has been the separation of air and water issues within funding agencies, to the extent that position descriptions
and job requirements do not encourage cross-media thinking. It was noted, however, that there is a growing movement
towards air-water integration in some agencies (e.g., EPA). The problem at the budget planning level has been the
inability to come to consensus on combining budgets for
air and water issues when each program has insufficient
resources to address important media-specific issues of
its own.
Joining the Media.
It is recognized that
"standards" are not fixed in time, and should evolve as
the science evolves. It was agreed that as society is
increasingly concerned about the development of coastal
habitats and the ability of communities to sustain living
standards along the coast, there is a glaring need to put
air in the equation. Critics worry about the availability
of funds tomorrow; so concerns must be articulated
effectively now. Currently, there are efforts underway to
start putting media together (land, air, and water) so that
we don't degrade one while benefitting another. The first
coherent federal program, initiated to put the different
issues and scientific specialties on a level playing field,
was the National Acid Precipitation Assessment Program
(NAPAP). In the Acid Precipitation Act of 1980,
NAPAP was authorized to coordinate applied research to
provide the scientific basis upon which Congress would
subsequently devise acid deposition control measures.
Through its experience, NAPAP has revealed that
connecting the media together is fairly unpopular,
because every time issues are "integrated," some program
stands to lose power or money.
Multidisciplinary
thinking requires the mind set that society wins, not that
one agency loses. The first step in creating a multi-media regulatory program is to recognize the need to
understand the entire system, its interactions and
economic consequences. The second step is then to
identify pressure points and devise appropriate strategies
and regulations for them.
It is constructive to recognize the lessons learned from the acid rain program of the 1980s. NAPAP's Oversight Review Board (ORB) reviewed the first ten years of NAPAP's scientific and assessment activities and developed nine lessons that it believes to be products of NAPAP's experience and which are part of its legacy. These lessons (see sidebar) represent a starting point for cross-media and trans-disciplinary research and integrated regulatory policy such as is the present focus.
4.4 Resolutions
Participants noted the continuing need to alert managers
and policy makers of the fundamental necessity to
consider interactions among atmospheric, terrestrial, and
aquatic systems when developing strategies for reducing
effects of pollution.
The meeting recommended an intensive effort to alert key decision-makers of the potential effects of
atmospheric decisions on aquatic and terrestrial ecosystems, of special importance in coastal areas. This
should begin by coupling processes mandated under the Clean Air Act and the Clean Water Act and their
amendments. (87% approval)
It was acknowledged that one cause of the communication problem is the use of language that is ambiguous. For
example, the word "reduction" is regularly used to mean "decrease" yet has a completely different meaning in scientific
circles (where it describes a chemical combination with hydrogen). The term "dry deposition" is another example.
In most modern usage, dry deposition is the turbulent exchange and surface capture of particles and trace gases from
the atmosphere, but in some circles it is limited to particles (at the exclusion of gases) and in others it is used to
describe deposition to artificial surfaces. The meeting summarized these concepts by agreeing that
As we move further into transdisciplinary endeavors it is important to have adequate communication among
specialists in different fields. Care should be taken to recognize and avoid using terms that cause confusion
among the contributing disciplines and the general public. (77% approval)
5.1 Issue: Maintaining Momentum
Inertia exists in all public and private environmental management systems. This inertia is evident in the strong preference by bureaucracies to continue with "business as usual," separating water and air regulatory issues. If a clear path can be charted, permitting air and water regulations to be constructed in a shared process, then management growth will be facilitated. A major goal of the present "Shared Resources" community is to rethink the air and water regulatory processes so that each can take the unique and specific requirements of the other into account.
5.2 Discussion: Should We Remain Engaged?
There is always frustration when trying to arrive at
consensus conclusions and recommendations. Though
some of the information that arises is outwardly
conflicting, it is better to provide this information than no
information at all. Dissenting opinions are a measure of
uncertainty, although not a very good one. Understanding
the reasons for the conflicting outcomes allows for a
much deeper understanding of the issues and of society's
response to the issues. This open architecture can lead to
a change and progression rather than passive acceptance of the reigning paradigm. The Shared Resources forum
provides a mechanism for sharing information about a rapidly evolving science that is actively engaging regulators
and policy makers. Participants at the workshop expressed frustration about the prevailing criticism that little is known
about the relevant science, that understanding of costs and benefits is lacking, that regulatory opportunities have been
missed and may now be beyond our reach, and that reductions will come our way anyway -- the so called "luxury"
reductions. Participants debated whether it is worth the effort to continue the shared resources fight. Why should we
not go our separate ways; wish each other well; try to save our own estuaries; let the air regulatory battles get fought
by others; and see what benefits result? There were several reasons mentioned at the workshop why we should remain
engaged..
1. Because air deposition is an important source of nutrients to coastal waters. The regulatory program did not walk
away from sanitary engineers or agricultural experts. It is well past time for air scientists and regulators to be heard
in the water arena.
2. Because limited efforts to date have had results. For example the rules generated under the acid rain provisions of
the Clean Air Act Amendments call for additional NOx emission reductions of 900,000 tons/year.
3. Because without careful attention, air decisions might miss the opportunity to benefit clean water (such as by relying
on seasonal fuel switching approaches rather than adopting emission reduction technology better suited to a year-around decrease in emissions rates).
4. Because the public relates to water-based resources and geographic areas, in some cases more than to air pollution
issues. Therefore, the results of the air pollution debate with water bodies engaged will result in more protection for
all of society and of our surrounding environment.
5. Because even if we decide not to deal with air pollution as a direct issue, society will eventually have to deal with
its manifestation in transportation planning and land-use changes arising from population growth in coastal
watersheds. It will be much tougher to address the issues of importance then; let's do our homework now and try to
work together on getting the reduction by staging ahead in our thinking.
5.3 Addressing the Issues: Remain Engaged
Link Science and Policy.
One of the weakest linkages is between science and policy. Excessive nutrients are a
problem with many waterbodies across the country. A level of comfort has been generated with reducing nutrient
loadings through effective water management and better nutrient management plans, but these options are reaching
their limits. Nitrogen sources and the relative importance of each source must be better characterized with emphasis
on determining how much is anthropogenic and how much is controllable. It is clear that atmospheric inputs to our
coastal waters are mostly a direct consequence of emissions, but it is not yet clear how to make the linkages between
individual and regional emission sources and deposition to specific watersheds and estuarine waterbodies. As estimates
are made, care is needed to express with clarity what is known and what is not yet known. In some cases the
uncertainty is daunting, especially in places where we are still lacking basic loading estimates.
It is also important that toxic chemicals be a part of the picture. More and more around the country exposure to toxic
chemicals and their bioaccumulation are emerging as air/water issues. In some lakes, almost all of the bioaccumulated
compounds arrive via the air deposition pathway. The participants acknowledged that it may be more difficult to
understand the air/water impacts from toxic, but they may be a more widespread problem.
The next biggest challenge is to link the multi-media
aspects of the problem. There is an historical
institutional separation of the media, and even when
air and water specialities are represented in the same
organization, there is often little communication.
Disciplinary expertise is useless unless placed in the
context of human health and welfare, which includes
ecosystem health and sustainability. Placing an
emphasis on air and water, emissions and deposition,
compliance costs and emissions reductions, physical
injury and economic damage is the most cost effective way to solve a large, complicated problem. Merely gathering
and reporting scientific knowledge does not guarantee its use in addressing the true concerns of society or in serving
public welfare. There is a need for more knowledge, but there is an even greater need for more understanding.
Recognize Issue in Current Efforts.
The amount of reduction needed to have a significant, positive effect must be
determined. One alternative is to advocate that the more reductions -- the better. However, society will continue to
be faced with the need to accept some truly economically-sustainable goal for reducing atmospheric inputs. Some
management programs have set overall reduction goals and realized that it might be easier to meet those goals if
atmospheric sources were reduced. The amount of reductions needed from each source remains unclear. In fact, the
process to develop these goals for reductions has yet to be solidified.
The proposal was made that our efforts continue down a middle track. The focus would remain on the regulatory
activities underway, the monitoring information coming from research, and the economic studies. At the same time,
some immediate actions would be taken:
include atmospheric inputs and subsequent effects in new source reviews associated with the "prevention of
significant deterioration" of coastal ecosystems, and include deterioration of water and aquatic habitat quality
among listings of "environmental effects" of air pollution,
investigate the potential for linking total maximum daily load (TMDL) pollutant allocations for impaired waterbodies
to air permit programs, and
increase federal sensitivities to the responsibilities under NEPA (National Environmental Policy Act) in order to
reduce a continued legacy of inability to work across media.
Identify the Paths.
After a specific goal is defined, how
do we actually achieve the emissions reductions that are
needed? Typically this is accomplished through
regulations and enforcement, but in the present case this
is complicated by the need to work at the intersection of
two laws. Can trading options be used across media?
The difficulty with relying on trading approaches is that
accountability for implementation is difficult to assess.
The question of seeking reductions using enforceable
controls versus unenforceable controls also remains an
issue.
We have achieved the first step of making the regulatory community aware of the air-water "shared resources" issue.
But, there needs to be more work on education. There should be a major focus on public education to help the public
make the linkages between personal action and water quality. Even after the public becomes informed about air and
water issues, there is still the possibility that they may not want to take the steps necessary to protect water resources
and aquatic habitats from air pollution impacts.
5.4 Resolutions
Finally, the community present at the Raleigh meeting agreed to have a continuing debate under the "Shared Resources
-- Airsheds and Watersheds" process. However, the participants failed to come to agreement concerning the
mechanism by which this might best be accomplished. Two alternatives were proposed:
The community involved in the coupled land and water science and regulatory issues will continue to
assemble at approximately 18 month intervals, as an ad hoc group of interested parties with no formal
umbrella (79% approval) .
The community present at the Raleigh Shared Resources meeting recognizes the need for an organizational
structure under which to operate, and supports efforts to attract a small level of funding from relevant
agencies to continue this endeavor. As part of this, a periodical newsletter summarizing relevant new
activities along all of the Atlantic and Gulf coasts would be prepared and circulated (73% approval).
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