Evaluating the Chesapeake Bay Program's Use Attainability Analysis for Nutrient Reduction Strategy

The U.S. Environmental Protection Agency's current effort to establish water quality criteria for the Chesapeake Bay has the potential to move the Bay toward a new level of use and enjoyment. It also has significant implications for the citizens of the watershed and their governments beyond guiding the enhancement of water resources. The criteria have the potential to dictate the need for, and the timing of billions of dollars in capital upgrades at municipal wastewater treatment plants and comparable investments by other sources of nutrients. This level of investment will affect the allocation of limited taxpayer resources and economic growth and development throughout the region.The EPA Chesapeake Bay Program Office's (CBPO) UAA approach is documented in the Technical Support Document for the Identification of Chesapeake Bay Designated Uses and Attainability (TSD-UAA).Because of the potentially large impact to its constituents, the Virginia Association of Municipal Wastewater Agencies (VAMWA) and the Maryland Association of Municipal Wastewater Agencies (MAMWA) evaluated the TSD-UAA with respect to use assessment, the cost of nutrient controls and the costs to control CSO and SSO. In addition, consideration was given to the potential of social impacts on growth and the displacement of growth to non-sewered areas. The evaluation included the potential of negative environmental impacts exceeding the benefits of the proposed EPA water quality criteria. The University of Cincinnati Economics Center for Education and Research was engaged to develop the means of evaluating these social impacts.The evaluation proposed the following:Support Water Quality Goals that can be met by 2010. Set these as targets under the Bay program for all to achieve. Do not set standards that are known to be unattainable.Develop an approach that encourages POTWs to install the most cost-effective controls, but does not impose caps that will lead to more environmental damage than the benefit provided.Consider the control of SSOs, storm water, and CSOs as a part of setting additional requirements on POTWs so these programs can proceed in priority of need