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Models and Water- Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

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Page 1: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Models and Water-Quality Trading

Pennsylvania SectionAmerican Water Resources Association

October 22, 2004Harrisburg, Pennsylvania

Cy JonesAquaCura

Page 2: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

A Brief History of Water-Quality Trading

Inspired by CAA SO2 Trading

1996 EPA Policy Statement

1996 EPA Draft Framework

2003 EPA Trading Policy

Page 3: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

What Is Water-Quality Trading?

Page 4: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Conventional Approach to Pollution Control

All WWTPs in the Watershed Must Meet Their Allocations

Capital Upgrades if Necessary

Nonpoint Sources

State Encourages Voluntary Programs

Hopes for the Best

Point Sources

Page 5: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Water-Quality Trading

WWTPs Can Exchange “Discharge Allowances”

WWTPs Can Acquire Nonpoint Source “Credits”

Nonpoint Sources

State Encourages Voluntary Programs

Hopes for the Best

Point Sources

Can Sell Pollution Reduction “Credits”

Page 6: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Necessary Preconditions for Trading

Individual Sources Assigned Pollutant Allocations and Required to Reduce Loads

Permit Limits for WWTPsDefined Baselines for Nonpoint Sources

Cost-differentials Among Sources for Pollutant Reductions

Freedom for Individual Sources to Decide How to Meet Allocation

Reduce Discharged Load

Buy Credits

Page 7: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Types of Water-Quality Trading

Water-Quality Goals Are Set

Analysis of Available Pollution-Control MeasuresLargest ReductionsCost-effectivenessAbility to Implement Quickly

Best Sequence and Timing for Upgrades is Determined

Managed Trading

Choose Initial Upgrades that Will Produce Reductions Greater than Needed to Meet Goals

Page 8: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Types of Water-Quality Trading

Non-Upgraded Facilities Must Purchase Credits from Upgraded Ones

Not All Facilities May Need to Be Upgraded

Managed Trading

Additional Upgrades Are Added as Needed to Comply with Goals

Connecticut Long Island Sound Nitrogen Trading Program

Page 9: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Types of Water-Quality Trading

Water-Quality Goals Are Set

Mass-load Limits or Goals Are Assigned to Existing Point Source Dischargers

The Dischargers Form a Trading Association

Trading Associations

Allocations Are Aggregated into a Single Association Allocation

Membership Is Voluntary

Page 10: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Types of Water-Quality Trading

The Association Is Free to Meet its Allocation in any Manner it Sees Fit

The Association Is Legally Responsible for Compliance

The Association Could Acquire NPS Credits

Trading Associations

Tar-Pamlico Trading AssociationNeuse River Compliance Association

Page 11: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Types of Water-Quality Trading

State Gives Allocations to Individual Dischargers

Buyers and Sellers Find Each Other and Negotiate Credit Sales

Cost Considerations and Market Forces Dictate Behaviors

Market-Like Trading

No Real Examples Yet

State Sets General Rules of the Market-Place

Page 12: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

How Can Models Be Used

in

Water-Quality Trading

???

But First...

Page 13: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

A Journey Through the Art of Water-Quality Management

If Heisenberg Had Been a Water-Quality Manager:

Dang!

I can’t be certainof anything!

Page 14: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Designated Uses

Most Are Generalized and Vague

Many Are Inappropriate

Scientifically Invalid

Unattainable

Difficult to Judge “Attainment” of Uses

There’s Never Enough Data

Page 15: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Numeric Water-Quality Criteria

Proper Development Requires Extensive Data

Known or Suspected Impacts of Substance of Concern

Water Body Physical Conditions, Chemistry, and Biology

Actual Instream Impacts

Wholesale Adoption of EPA Criteria?

Page 16: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Numeric Water-Quality Criteria

Wholesale Application of a Single Generic Criterion to a Variety of Water Bodies?

Are Criteria Easily Comparable to Reasonably Obtainable Monitoring Data?

There’s Never Enough Data

How Do You Interpret Compliance with a Criterion?

Page 17: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Narrative Water-Quality Criteria

Don’t Even Go There!(1)

(1) Except on Rare Occasions

Page 18: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Identification of Impaired Waters

Proper Assessment Requires Extensive Data

Data Quality a Concern (Use any Old Available Data)

Many Waters Listed on 303(d) Lists with Little Certainty about Actual Status

When Is a Water Body Truly Impaired?

There’s Never Enough Data

Page 19: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Determining Actual Pollutant Loads

Point Sources - Not a Problem

Nonpoint Sources - Big Problem

Many Factors Affect Agricultural Loads

Soil TypeSlopeCrop TypeFertilizer Application RateWeather

Scientific Uncertainty

Non-Random Variability

Random Variability

Page 20: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Determining Actual Pollutant Loads

There’s Never Enough Data

Page 21: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Determining Allowable Pollutant Loads

Some Sort of Analytical Framework is Needed

A Host of Issues

Data Needs

Model Selection and Validity

Analytical Uncertainty

Prediction Reliability

Selection of Proper Design Conditions

Scientific Understanding

Page 22: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Determining Allowable Pollutant Loads

There Is Never Enough Data

Page 23: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Assigning Pollutant Reduction Responsibilities

Certainty of Reductions?

Point Sources - Yes

Uncertainty and Variability in NPS Loads

Nonpoint Sources - Not Usually

There’s Never Enough Data

Uncertainty and Variability in BMP Performance

Page 24: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

Determining Water-Quality Results

Adequate Post-Implementation Monitoring and Analysis?

There’s Never Enough Data

Page 25: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

An Inventory of Uncertainty

The Political Context

Water-Quality Management Is Ultimately a Public and Political Process

Empirical Data Won’t Help You

Page 26: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Which Brings Us Back to...

The Art of Water-Quality Management

Science Cannot Really DeliverWhat the Political Process of

Water-Quality Management Demands

Page 27: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

How Can Models Be Used

in

Water-Quality Trading

???

Page 28: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Water-Quality Models and Trading

Trading Should Be Evaluated Using the Same Analytic Framework Used to:

Adopt Designated Uses

Develop and Adopt Criteria to Support Uses

Determine Attainment Status

Determine Pollutant Sources

Page 29: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Water-Quality Models and Trading

Trading Should Be Evaluated Using the Same Analytic Framework Used to:

Relate Water Quality to Pollutant Sources and Loads

Assign Pollutant Reduction Responsibilities

Assess Water-Quality Results

Page 30: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Water-Quality Models and Trading

All of Our Analytic Frameworks Are Imperfect

Most [models] are little different than those developed in the1960s and 1970s for dry weather wasteload allocation…

Paul Freedman, 2001The CWA's New Clothes. In: Water Environment & Technology 13(6) 28-32

Worse yet, many models have complex detailed input requirements, so many people assume that the calculations are more precise and accurate than they really are...

and little guidance on testing model adequacy or reliability is available.

Page 31: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Rational Action in the Face of Uncertainty

Recognize Shortcomings in Water-Quality Management

Balance the Needs

Balance the Risks

“Sound Science”

Action

Delay or Inaction while Awaiting the Science

Wasting Scarce Resources in Implementing Needless or Ineffective Requirements

Page 32: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Rational Action in the Face of Uncertainty

“Allow for an iterative (or adaptive or phased) approach in cases of uncertainty or lack of success in achieving standards”

Report of the Federal Advisory Committee on the Total Maximum Daily Load (TMDL) Program 1998

Iterative Approach

Page 33: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Rational Action in the Face of Uncertainty

“Using the best tools and data available, we should make best estimates and take action, recognizing that the decision and action may not be final. If we work to explicitly define the range of uncertainty in our analysis, we can act within that range. Then if, as part of the TMDL, we monitor progress and later adapt our actions, we can continue to progress toward clean water.”

Paul FreedmanThe CWA's New Clothes

Adaptive Management

Page 34: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Rational Action in the Face of Uncertainty

“It is a process of taking actions of limited scope commensurate with available data and information to continuously improve our understanding of a problem and its solutions, while at the same time making progress toward attaining a water quality standard. Plans for future regulatory rules and public spending should be tentative commitments subject to revision as we learn how the system responds to actions taken early on.”

National Research Council, 2001Assessing the TMDL Approach to Water Quality Management

Adaptive Implementation

Page 35: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Cautionary Tales

A Comparison of Three Modeling Approaches:

Stow C. A., Roessler C., Borsuk, M. E., Bowen J. D., and Reckhow K. H., 2001American Society of Civil Engineers Journal of Water Resources Planning and Management. 129(4):307-314.

Comparison of Estuarine Water Quality Models for Total Maximum Daily Load Development in the Neuse River Estuary

Neuse Estuary Eutrophication Model (NEEM) A Two-dimensional, Mechanistic Model

Water Analysis Simulation Program (WASP) A Three-dimensional, Mechanistic Model

Neuse Estuary Bayesian Ecological Response Network (Neu-BERN) A Bayesian Probabilistic model

Page 36: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Cautionary Tales

Conclusions of the Study Team:

Stow C. A., Roessler C., Borsuk, M. E., Bowen J. D., and Reckhow K. H., 2001American Society of Civil Engineers Journal of Water Resources Planning and Management. 129(4):307-314.

Comparison of Estuarine Water Quality Models for Total Maximum Daily Load Development in the Neuse River Estuary

None of the models were deemed to be able to offer satisfactory performance for the purpose of explicit chlorophyll a predictions for all sections of the estuary.

“Even in a well-studied, data-rich system, accurate prediction is difficult.”

Models should be used in a collaborative atmosphere, with ample stakeholder involvement, to provide “quantitative guidance rather than a definitive number.”

Page 37: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Cautionary Tales

The Chesapeake Bay’s Pesky Pycnocline

Refined Designated Uses forChesapeake Bay and Tidal Tributary Waters

A. Cross Section of Chesapeake Bay or Tidal Tributary

B. Oblique View of the “Chesapeake Bay” and its Tidal Tributaries

Shallow Water

Open WaterDeep Water

Deep Channel

Open WaterHabitatShallow Water

Habitat

Deep Water

Deep Channel

Migratory FinfishSpawning andNursery Habitat

Source: Chesapeake Bay Program

Page 38: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Cautionary Tales

The Chesapeake Bay’s Pesky Pycnocline

Source: Chesapeake Bay Program at http://www.chesapeakebay.net/ecoint3a.htm

Page 39: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

CB4 Deep Water Drives “Attainment”

CB4

Source: Chesapeake Bay Program

Page 40: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Cautionary Tales

The Chesapeake Bay’s Pesky Pycnocline

Some Amusing Events:

February, 2003 PSC Debates Baywide Nitrogen Load Goal

175 M lbs/Yr 99.1 % CB4 D.O. Attainment

Versus

198 M lbs/Yr 98.1 % CB4 D.O. Attainment

Cost Difference $430 M per Year

PSC Selects 175 M lbs/Yr as the Goal

99 % Attainment Is the Minimum Acceptable Level

Page 41: Models and Water-Quality Trading Pennsylvania Section American Water Resources Association October 22, 2004 Harrisburg, Pennsylvania Cy Jones AquaCura

Cautionary Tales

The Chesapeake Bay’s Pesky Pycnocline

Some Amusing Events:

Sometime Later, 2003

Bay Modelers “Tweak” the Pycnocline Definition

New Model Runs:

175 M lbs/Yr ~ 93 % CB4 D.O. Attainment

Fall, 2004 Maryland Proposes “Restoration Variance” for CB4 D.O. Standard

OOOOOPS!