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Keynote Address Delivered At The Annual Meeting of the Food Industry Environmental CouncilTampa, FL - March 17, 2003
Delivered by G. Tracy Mehan, IIIAssistant Administrator for Water, U.S. Environmental Protection Agency
Introduction Thank-you for inviting me to speak today. I am very pleased to be able to represent EPA and the Office of Water at this 33rd annual conference on Environmental Engineering in the Food Processing Industry. Experts, like yourselves--who face the challenge of environmental compliance and development of control technologies every day--are a key resource. You are integral to the development of the innovative solutions that will be necessary as we confront the water problems of the 21st century. Sharing ideas and information is an important part of the foundation for the development, implementation, and generalized application of improved technologies and environmental management systems. Population and economic growth and related pressures continue to place heavy demands on one of our most precious and increasingly scarce resources--clean freshwater. It is very clear that without continued technological and management innovations we will not be able to maintain existing levels of water quality, much less make progress in the future. Thus, we must find ways to foster innovation. We must ensure that our regulatory approaches include tools and methods that are more flexible and finely tuned. And we must judge the success of these approaches by real results. This meeting provides an ideal opportunity to share my thoughts on the challenges that we face in protecting the Nation’s waters and the tools–old, new, and yet to be developed--that we may have available to address these challenges in the future. I was very pleased to see that your agenda includes sessions on many of the approaches that the Agency is trying to promote including: conservation and environmental management systems. I was even more pleased that these topics, focused on prevention, appear at the beginning of the agenda. I commend you on the direction you are taking.
Remaining Challenges EPA Administrator Christie Todd Whitman has stated publicly many times her belief that water quality and quantity issues will pose the greatest environmental challenge of the 21st century. On October 18, 2002 we marked the 30th anniversary of the Clean Water Act–taking great pride in the progress that has been made and the fact that there has been a dramatic increase in the number of waters that are once again safe for fishing, swimming and other activities. Despite these accomplishments in improving water quality, it is clear that we must keep progressing. I would like to give just one example of why we cannot even stay where we are by standing still. When considering biological oxygen demand (BOD), without continued investments and improvements in wastewater treatment, resulting in increased removals of pollutants, future population growth will erode away many of the CWA achievements in effluent loading reduction to the point that by the year 2016, BOD loading rates could be similar to those experienced in the mid-1970's. Further, increased and improved monitoring give us an indication of the scope of the current challenges which remain. State-reported monitoring data collected in 2000 shows that approximately 40% of waters assessed by States still do not meet basic water quality standards. Remaining water quality problems are not easily remedied: they come not just from pipes, but from diffuse sources – farming and forestry, construction sites, urban streets, automobiles, atmospheric deposition, even suburban homes and yards. They are no longer just chemical in nature. There are biological threats to our nation’s waters that we must address as well if we are to truly achieve the stated goal of the Clean Water Act to "restore and maintain the chemical, physical, and biological integrity of the Nation’s waters". As we address these different and more subtle challenges we will need to place even more emphasis on ensuring that we support and encourage the technological developments and environmental management improvements that are the underpinnings of sustained progress.
What Tools Are Most Appropriate to Address These Issues? As we think about these challenges, it is apparent that the Clean Water Act has enabled us to make great but not all-encompassing progress, and it is now being tested against different challenges than those it has been most effective against in the past. To succeed against these different challenges, we believe it will take new approaches, to complement but not replace existing ones. Our solutions will have to be multi-faceted with federal, state and local, public and private investment of time, energy, resources, research and, perhaps most needed, innovative thinking and broad public involvement. Today I would like to discuss four elements that I think are key to success in meeting the new challenges which we face and which are most relevant to your concerns in the food processing industries. These are: the watershed approach (including water quality trading), environmental management systems, efficiency/full cost pricing, and innovation.
The Watershed Approach The past decade has seen a shift towards an emphasis on what is now commonly referred to as the watershed approach. This approach focuses multi-stakeholder efforts within hydrologically defined boundaries to protect and restore our aquatic resources and ecosystems. EPA has been promoting, and many governments have been practicing it in their work. I have recently taken steps to rededicate all of the Office of Water to this approach because I firmly believe that it offers the most cost-effective opportunity to tackle today’s challenges. Administrator Whitman shares my belief. She feels strongly that a watershed or "place-based" approach is one of the most important environmental guiding principles for her as well as for this Administration. EPA views watersheds as the basic unit to define and gauge the nation’s water quality. Our actions to restore America’s streams, lakes, and rivers must be based upon improving the watersheds which unite not just our rivers and streams, but our communities, and thereby bind together our lives with our environment. The watershed approach enables us to address the problems of greatest concern in a comprehensive, effective manner, and through cooperation with affected stakeholders to maximize our results with limited resources. Leading the way are over 4,000 local watershed organizations in the U.S. working to advocate watershed restoration, source water protection, improved site design, erosion control, land conservation, storm water management and many other aspects of water resource management. In rededicating to the watershed approach I have asked our senior managers, among other things, to identify ways to increase our training and technical assistance for these local, state, and tribal watershed partnerships. In the context of the watershed approach, I would like to focus on several tools that are very appropriate to address the more complicated challenges we now face. These tools, which take on many new aspects when considered in the context of the watershed, are TMDL’s, permitting, and water quality trading.
TMDL’s EPA has been encouraging States to develop and implement TMDLs on a watershed basis. Our hope is that this approach will greatly increase collaboration and support for the needed pollutant controls. Increased public involvement is vital in several respects. Because TMDLs are water quality based, they are information intensive, requiring widespread and systematic monitoring to identify and characterize problems and priorities, and to track progress in solving them. Public involvement can contribute to providing this information as well as liberate the creative energies of those most likely to benefit from reduced pollutant loadings to their own waters. Opening the deliberations to all stakeholders and allowing time for innovation also provides additional opportunities to take advantage of other programs, including Non-point Source grants under the Clean Water Act, the conservation provisions of the newly re-authorized Farm Bill, the source water assessment requirements of the Safe Drinking Water Act, and other federal, State and local programs. Greater inclusiveness and time in the process are especially important because these programs are diverse and require a substantial amount of coordination among agencies, levels of government, and specific aspects of the various programs. The TMDL program continues to evolve to meet the challenges of cleaning up our Nation’s waters. Several regulatory changes to the TMDL program have been under consideration. At the same time there have been many non-regulatory improvements to the program that have resulted in States increasing the quality of their impaired waters listings and greatly accelerated the pace of their TMDL development. These non-regulatory improvements include issuance of TMDL technical guidance, monitoring guidance, and CWA section 319 nonpoint source guidance to help States develop better methods to more accurately and consistently monitor and list impaired waters, establish TMDLs, and identify the most appropriate and cost-effective methods and approaches to implement the TMDL program.1 Most recently EPA withdrew the July 2000 final rule which would have revised the TMDL program. Currently the Agency is continuing to implement the existing TMDL program. Between 1996 and 1999, EPA and the States established approximately 800 TMDLs. Since then, and despite the fact that the July 2000 rule never became effective, more than an additional 7,000 TMDLs have been established. Moreover, mechanisms are in place to ensure that those efforts do not diminish. Currently, there are 22 States in which EPA is under court order, generally resulting from entry of a consent decree, to establish TMDLs if States do not do so. As this work progresses we are continuing to review the ongoing implementation of the existing program with a view toward continuous improvement and possible regulatory changes in light of stakeholder input on the July 2000 rule and the National Academy of Sciences’ National Research Council’s report which made numerous recommendations for improving the rule and the program, which were not reflected in the July 2000 rule.
Permitting Integrating our NPDES permitting system into a community’s watershed management plan will result in more efficient and environmentally focused management. A number of states are adopting a statewide watershed approach to permitting and I am working to expand our efforts to assist those States. I have directed our Office of Wastewater Management to accelerate its efforts to support authorized States and regions to issue NPDES permits on a watershed basis. This includes issuing, in January of this year, a watershed-based permitting policy statement and working with the regions to: develop and implement a "roadmap" for advancing watershed-based permitting; implement the watershed-based permitting policy immediately in those regions that administer the NPDES program; identify watershed-based permit case studies and create pilot programs; and determine permits or groups of permits that may be a high priority for re-issuance based on watershed specific goals, impacts, and expected results.
Water Quality Trading Watersheds are ideal for experimenting with market-based incentives. Our Water Quality Trading Policy2 released on January 13th of this year renews our efforts to pursue water-quality trading for nutrients, sediments, and other pollutants to reduce the overall cost of compliance with water quality based requirements. With this policy, we are supporting States and tribes in developing trading programs that meet the requirements of the Clean Water Act. A water quality "credit" could be created by reducing pollution loads beyond the level required by, say, the most stringent water quality based requirement. Or, for example, an unregulated landowner or a farmer could create credits by changing cropping practices and planting shrubs and trees next to a stream. A municipal wastewater treatment plant could then purchase and use these credits to meet water quality limits in its permit. Trading for TMDL implementation offers particular promise for its water quality and economic benefits. Our policy supports trading among and between regulated and unregulated sources. In its analysis of the Clinton Administration’s Clean Water Initiative, EPA concluded that the total potential saving from all types of trading range from $658 million to $7.5 billion annually.3 A current example of a successful trading effort, between point sources only, can be found on Long Island Sound where nitrogen trading among publicly owned treatment works in Connecticut is expected to save over $200 million in control costs. A study of three watersheds in Minnesota, Michigan and Wisconsin by the World Resources Institute (2000)4 found that the cost of reducing phosphorous from point sources, traditional pipe-in-the-water dischargers, was considerably higher than those based on trading between point and non-point, or diffuse, sources of runoff which are not regulated by the Clean Water Act. The estimates for point source controls ranged from $10.38 per pound of phosphorus in the Wisconsin watershed to $23..89 in the Michigan watershed. Using trading between point and non-point sources, these costs could be lowered to $5.95 per pound in Wisconsin, a reduction of over 40%, and to $4.04 in Michigan, a reduction of over 80%. Clearly if we use some or all facets of these interrelated tools: TMDLs, permitting, and water quality trading, in the context of an integrated watershed approach we can more efficiently and more effectively address clean water and drinking water needs.
Environmental Management Systems Judging from your agenda and the large number and variety of your member organizations participating in the session on Environmental Management Systems (EMS), I believe that I am "preaching to the choir". Still, I want to touch on EMSs because I believe they are an important tool for addressing water issues and are clearly an area where we can learn from each others experiences. EMSs are a potentially powerful tool to reduce a range of environmental impacts, some of which may not be amenable to regulation (e.g. odor, noise, energy consumption, or water consumption). In conjunction with reducing environmental impacts, EMSs offer other benefits including cost savings, increased operational efficiency, risk reduction, improved internal communications, and improved relations with external parties. I came to EPA knowing something about EMSs and was quite pleased to see a lot of work at the Agency devoted to EMSs. EPA has been involved in strategically promoting the voluntary adoption of EMSs for several years. Over the past few years we have devoted a lot of attention to working with local governments that want to adopt EMSs. Since 1997 we have assisted 23 local agencies around the country and we are beginning work with another 12 agencies. We have worked with people in agriculture like the United Egg Producers to develop a voluntary EMS program and are now doing the same with the wastewater industry through the National Biosolids Partnership. Later this afternoon, I will be meeting with the American Meat Institute which is heavily involved in piloting a meat and poultry industry EMS. Through EPA’s Meat Processing Sector Program, the Agency has partnered with AMI member companies and the State of Iowa to pilot test the "EMS Guide for the Meat and Poultry Processing Industry," an EMS implementation tool tailored to meet the industry’s needs. The guide consists of ten modules covering policy, planning, implementation and operation, checking and corrective action, and management review. Among the lessons we learned from this project is the need to tailor our EMS assistance activities to meet the unique needs of a particular industry sector, including the creation of tools that help trade associations make a business case to their members to develop EMSs. I also want to take a moment to commend AMI on its multi-tier "Environmental MAPS" Program, which is now under development. As I understand it, this Program is designed as a "road map" to help meat processing facilities improve their environmental performance in a stepwise manner, from basic policy statements and compliance criteria, to more comprehensive requirements, to EMS development (using the guide that we developed with AMI), to ISO 14001 certification for firms that wish to do so. This program reflects AMI’s commitment to improved environmental performance of all of its members. All of our experiences to date tell us that EMSs work. They are helping organizations of all types reduce their environmental "footprint", prevent pollution, improve compliance, build better relationships with communities, and save money. Looking ahead, I would like to see EPA and others use EMSs even more. I would also like to see more research in this area. I know that much has been done, but EMSs are such a new topic that we can all benefit from learning more from the research community.
Efficiency/Full Cost Pricing In addition to managing better, we are going to have to learn to use water more efficiently. At the end of 2002, nearly half of the continental U.S. was in drought. In addition to reduced rainfall, most of our water systems also face a growing population and economy. Moreover, we are reaching the end of the era in which we could always expand water supply. As our waters are more stretched across competing demands, our supply side approach to water management will have to be coupled with demand side management. During the next 100 years, we are going to have to become experts on the demand side of the equation: conservation, recycling, reuse and improved water-use efficiency. In addition to managing better and using less, we are going to have to pay more of the actual costs of maintaining our water systems over time. This is a proposition that is, perhaps, better received when I talk with those who supply the water rather than those who use it. Nevertheless, I know it is a subject that is important in your industries as the result of the large water demands for cleaning and sanitizing to meet the regulatory requirements of USDA and FDA and for processing our foods. The Congressional Budget Office recently issued a report entitled Future Investment in Drinking Water and Wastewater Infrastructure5 which points out that increased future infrastructure costs will either have to be paid by taxpayers or ratepayers. To quote CBO: "Ultimately, society as a whole pays 100 percent of the costs of water services, whether through ratepayers’ bills or through federal, state, or local taxes." CBO raises strong efficiency arguments for ratepayers picking up the increased costs rather than taxpayers. In addition, we know that when prices rise, quantity demanded falls. Our goal it to have rates that are affordable, but not so "muffled" that we cannot hear a price signal, a signal which conveys important information on the true cost of the resource being provided.
Innovation Finally, I want to return to the subject of innovation which as I said earlier, is the underpinning of sustained progress. Our aim is to use the tools we have discussed in ways that will foster innovative solutions–through technology, better management, market incentives, and by viewing and addressing our water issues in an integrated way--based on the watershed approach. I also left innovation until the end because I wanted to close with a brief look at one of our "old" tools that is undergoing some substantial innovation itself–the effluent guidelines program. This program’s direction for the past 20 years has been dictated by a court-ordered consent decree. Now, for the first time in a long time, we have the ability to shape the direction of the program, to make the right kind of environmental decisions that are both legally defensible and practical. Through a participatory and transparent process we are looking at identifying sources of water quality problems and deciding whether effluent guideline development or revision is an appropriate way to address the risk identified. We are proposing a process to establish priorities for guideline development or revision that is predicated on selecting opportunities for the greatest risk reduction using the best programs and tools available. Existing effluent guidelines will be examined to see if their revision might eliminate inefficiencies or impediments to technological innovation, or to promote innovative approaches such as water quality trading, including within-plant trading. In our consultations with stakeholders during the development of the proposed effluent guideline planning process, stakeholders emphasized the importance of using the guideline selection process as an incentive to encourage industries to implement voluntary pollution reduction efforts–by giving lowest priority to industries that have reduced their pollutant loadings the most in recent years. EPA agrees that voluntary efforts should be encouraged and rewarded, especially where those voluntary reductions have been widely adopted within an industry and have led to significant reductions in pollutant discharges. EPA may choose not to revise an existing guideline or develop a new guideline for an industrial category that has demonstrated that significant progress is being made through voluntary industry effort to reduce risk to human health and the environment. In certain cases, if the Agency determines that developing a new or revised effluent guideline is not appropriate, we would attempt to identify other Agency actions that may be appropriate to address any remaining risk. Such action may include the issuance of compliance or permitting guidance, technical assistance to States or industry, or a voluntary partnership to support broader environmental goals. EPA will build on a base of experience we already have in these areas. For example, we are working with American Meat Institute member companies, the State of Iowa, and others to test voluntary approaches to implement Combined Nutrient Management Plans that will reduce non-point impacts in a more effective, less costly manner. In another example drawn from our work with the agribusiness sector, we will expand our EMS pilot work in strategic ways to help your member companies adopt more efficient approaches to dealing with certain types of environmental issues. Transparency and stakeholder inclusion have been essential to the development of the proposed effluent guideline strategy and we are committed to continuing this as we refine the strategy and begin to implement it. I encourage you to participate in this process.
Conclusion We have made tremendous progress in cleaning up our waters over the past three decades --an achievement that is even more remarkable in coming alongside substantial increases in population growth and often-dramatic economic growth. As a nation, we can be proud of how far we've come, and of the partnerships among all levels of government, the private sector and America’s citizens that enabled us to get there. Although there is much that remains to be done, those remarkable achievements should strengthen our resolve to persist in facing the tough work still before us. This work will require: continued investment in infrastructure and technological innovation, and the use of more focused strategies and more finely tuned and flexible tools that spur innovation and excellence in environmental management, promote a watershed approach to pollution prevention, and expand use of market based incentives to improve the quality of the Nation’s waters. These are all important elements of the shift in paradigms that is necessary to make sustained progress in cleaning up America’s waters. These are our challenges and, while daunting, our common goal of clean and safe water for the nation will help ensure that substantial progress will continue in the 21st century. The contributions which you make in developing improved technologies, processes and management systems makes all of this work easier–our goals become not only more obtainable–but more easily achieved. I thank you for your attention and look forward to the information and sharing of ideas that this conference will provide as we continue to fine-tune our techniques for protecting our Nation’s waters.
1. A complete list of these documents can be found at EPA’s website: http://oaspub.epa.gov/waters/national_rept.control. 2. EPA, Office of Water, Final Water Quality Trading Policy, January 13, 2003. Website: http://www.epa.gov/owow/watershed/trading/finalpolicy2003.html. 3. EPA-800-R-94-002, Office of Water, President Clinton’s Clean Water Initiative: Analysis of Benefits and Costs, March 1994. 4. Paul Faeth, Fertile Ground: Nutrient Trading’s Potential to Cost-effectively Improve Water Quality, Washington, D.C.: World Resources Institute, 2000. 5. Congressional Budget Office, Future Investment in Drinking Water and Wastewater
Infrastructure, November 2002, ISBN 0-16-01243-3. |
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