G. Tracy Mehan III, a frequent contributor to WaterWired, executive director for government affairs at the American Water Works Association and adjunct professor at the Antonin Scalia Law School at George Mason University recently (29 July 2019) keynoted at the 74th Annual Conference of the Soil and Water Conservation Society in Pittsburgh, PA.
Download GTM_Keynote_Address_74th_SWCS_Intl_Annual_Conference_2019
Be sure to read the entire address; it's only 10 double-spaced pages. I will highlight the portions that made a particular impression on me.
Here are the first few paragraphs.
Good morning. It is a privilege to kick off the Society’s 74th annual conference, the first since passage of the new Farm Bill. I want to thank Clare and all the members of the Society for inviting me to offer the perspective of the American Water Works Association (AWWA), its 50,000 individual members and over 4,000 drinking water utilities across the United States. We share your quest for sustainable agriculture recognizing the importance of food and water to all Americans.
My own personal involvement with agriculture goes back to my days as director of the Missouri Department of Natural Resources and its robust soil and water program, supported by a parks-soils sales tax voted in, many times, by a referendum of the voters of the state. Subsequently, while working on Great Lakes issues in Michigan, I had the privilege of providing staff support for the Governor who co-chaired the National Forum for Nonpoint Source Pollution convened by the National Geographic Society and The Conservation Fund from 1993-1995.
Some more snippets....the Great Lakes and more:
More recently, I have also come to understand the impacts of nonpoint source pollution and agricultural runoff, not just on ambient water quality, but also our nation’s drinking water supply and public health. Recent history provides ample evidence.
In August of 2014, an algal bloom in western Lake Erie produced a toxin known asmicrocystin in the part of the lake from which the city of Toledo draws its drinking water. For three days, the city issued a “do not drink” advisory affecting more than 400,000 people served by its water system.
Still more...
Although every watershed is unique, and each has its own mix of nutrient sources, Lake Erie and the other Great Lakes have been subject to regulation of point source discharges (i.e.,the traditional discrete pipe or conveyance of pollution) under USEPA’s Clean Water Act formany decades. Yet, across North America, some of the most prominent sources of nitrogen and phosphorus are nonpoint sources such as diffuse runoff from regulated urban stormwater and unregulated agricultural stormwater. While regulation of urban storm water continues to advance, voluntary partnerships to help address concerns from agricultural lands remains the greatest opportunity for meaningful progress on these private lands.
The Toledo area includes plenty of row crop agriculture that ultimately drains into the Maumee River watershed, tributary to the part of western Lake Erie where the City takes its raw water. These agricultural nonpoint sources, except for large, concentrated animal feeding operations, are not regulated under federal law. Furthermore, they are unlikely to be regulated in the future given the breadth and reach of agricultural operations in the United States.
The recognition of the relationship between agriculture, the land as it were, and water quality is not new. In 2004, just after stepping down as head of EPA’s water office, I penned an article of the Journal of Soil and Water Conservation (July/August) on “Successful Watershed Management,” in which I opined that “Water quality managers must now look to the entire watershed not just isolated sources of pollution-to nonpoint sources not just point sources.” Moreover, “water quality managers now find themselves ‘playing without the ball’ at least with respect to diffuse, nonpoint sources which are mostly within the province of other agencies, local governments or private sector entities or individuals. These managers must coordinate their objectives with those of other players, throughout the watershed.”
More on drinking water:
Basically, utilities use a “multiple barrier approach” to provide the public adequate quantities of high-quality water at affordable rates. This approach is comprised of (1) selecting the highest-quality source water possible; (2) protecting the source; (3) treating the water; (4) maintaining quality in the distribution system; (5) monitoring quality at all these stages; and (6) when necessary, if the other barriers fail, implementing emergency response procedures. This is all set out in AWWA’s G300 standard many copies of which I have been distributing around USDA headquarters of late.
Source water protection (SWP) is related to watershed protection but is different in that it entails a tighter focus on sources of potable water and public health rather than only ambient water quality under the Clean Water Act. It might be helpful to conceive of these two concepts as a kind of Venn diagram with source water protection partially but not entirely overlapping with watershed protection.
“The primary objectives of SWP [Source Water Protection] programs are to maintain, safeguard, and/or improve the quality of a given water source…pollution prevention is often preferable to remediation or treatment of contaminated source water” (Gullick 2017). The benefits derived from this preventative approach include treatment cost savings, increasing public health protection and, in the case of some land-based practices, generating other environmental benefits such as habitat for endangered species, and protecting air quality.
Our G300 standard posits six main elements of developing and implementing a successful SWP program are:
1. Vision
2. Stakeholder involvement
3. Source water characterization
4. Goals
5. An action plan
6. Periodic evaluation and revision of the program.
Almost three years ago AWWA embarked on a sustained effort to forge effective partnerships with the U.S. Department of Agriculture (USDA), Congress and the agricultural community to promote SWP as part of AWWA’s Total Water Solutions initiative. In addition to the advocacy efforts to incorporate source water protection into the Farm Bill and in implementing rules, AWWA has assisted several utilities in preparing applications to the Regional Conservation Partnership Program (RCPP) based on models developed by pioneering utilities in Arkansas, Iowa and New England.
My last snippet (really!):
AWWA’s major legislative objective was to incorporate SWP as a basic program element in USDA and NRCS through the reauthorized Farm Bill. Besides advocating for funding for the conservation title (Title 2 of the Farm Bill, the portion of the overall law that lays out conservation policy and funding) to be maintained at current levels, or even increased, and that conservation policy gains from the Agricultural Act of 2014 be retained, AWWA advocated for an explicit emphasis on the following areas:
• Protect source water to safeguard potable water and public health
• Expand opportunities for the NRCS to work with water systems to prioritize SWP
activities in each state
• Increase benefits for farmers who employ practices that benefit downstream water quality
• Require that at least 10 percent of conservation program funds focus on the protection of drinking water sources. Furthermore, the Secretary of Agriculture should be authorized to work with drinking water utilities and State Technical Committees to identify local priority areas in each state.
On December 12, 2018, Congress passed and on December 20 the President signed afive-year Farm Bill (P.L.115-334) containing virtually all of AWWA’s requests to strengthen the protection of drinking water sources, as described in Section 2503. The Agriculture Improvement Act of 2018 will contribute at least an astonishing $4 billion over 10 years to source water protection, as a floor not a ceiling. The bill also increased authorized funding for the RCPP to $300 million along with streamlining the program’s administrative process.
Well, I just summarized the letter by reproducing about half of it. Just read it all.
Enjoy!
"You know how you always say you learn just as much from teaching your classes as your students learn from taking them? Well, we decided to charge you tuition." - @ass_deans
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