March 2011, Vol. 23, No.3

All eyes on Florida


U.S. EPA’s numeric nutrient standards raise questions, concerns

Since the U.S. Environmental Protection Agency (EPA) promulgated nutrient criteria for Florida’s fresh waters on Nov. 14, the rest of the country has been watching. This is the first time EPA has stepped in to set numeric criteria for a state. Those in the regulated community want the best science to guide decision-making and are looking for certainty that the number is right and that they can meet it. 

But science is inherently uncertain, and there is not enough funding or time to produce the perfect nutrient criteria for each unique waterbody in the state. Expressing the criteria in a probabilistic way and pursuing adaptive management will go a long way toward addressing some of these challenges, experts say.

Until now, Florida and most other states have relied on narrative nutrient criteria that simply forbid nutrient concentrations that impair aquatic ecosystems. “But narrative criteria can be vague, subject to interpretation, and often result in an impaired condition, like an algal bloom, before you know you have put too much in,” said Mark Clark, a wetlands ecologist at the University of Florida in Gainesville.

EPA declared in 1998 that narrative standards were no good and ordered states to develop numeric criteria by 2003. A numeric standard defines the maximum concentration of phosphorus or nitrogen that will enable waterbodies to maintain their designated use, such as swimming or native fish habitat.

To date, only five states — Hawaii, New Jersey, North Carolina, Oregon, and Vermont — have complied with EPA’s mandate for rivers and streams. Meanwhile, the frequency and duration of algal blooms and their attendant “dead zones” of low oxygen are increasing across the country, said Amy Parker, a private consultant in Athens, Ga., and former national nutrient coordinator at EPA.

Although Florida had spent nearly $20 million since 1999 to develop numeric nutrient criteria, the Florida Wildlife Federation (Tallahassee) was frustrated by the state’s slow-footed effort and sued EPA in 2008. In a court settlement, EPA agreed to issue final numeric criteria for Florida’s fresh waters by Nov. 14, 2010, and to propose criteria for coastal waters by Nov. 14, 2011. Other states are closely watching the action unfold in Florida, anticipating that more environmental groups will sue EPA to set numeric standards for the noncomplying states, Parker said.

Since EPA issued Florida’s final freshwater nutrient criteria, a number of industrial and agriculture groups have filed suit. A common complaint in these lawsuits is that the nutrient targets are based on faulty science and could lead to expensive retrofits in exchange for little improvement in water quality. “However, the relationship of nutrients to water quality is one of the most powerful pieces of predictive science in the environmental field and is written into laws across the world,” said John Downing, a limnologist at Iowa State University (Ames).

Downing said that most scientists support the three main approaches that EPA used to determine Florida’s nutrient criteria. The preferred method is called a “stressor–response relationship,” which correlates data on nutrient concentrations to biological responses, such as chlorophyll a and dissolved-oxygen levels. If there are insufficient field data to calculate a stressor–response relationship, researchers turn to a reference approach in which the distribution of nutrient concentrations in healthy waterbodies nearby is identified. In systems with lots of data, EPA has employed mechanistic models that calculate nutrient dynamics in a watershed to predict how lakes, streams, and estuaries will respond to enrichment. “But EPA might consider biological approaches, such as looking for actual break-points in relationships between water quality and things like species-richness and diversity, that could yield strong evidence of the relationship between water quality and biological integrity,” Downing said.


Tension over divergence and uncertainty
To account for natural variability in hydrology and geochemistry, EPA divided Florida into four ecoregions and proposed nutrient criteria for colored, alkaline, or acidic waterbodies in the regions.

But the size of Florida’s nutrient ecoregions is not fine enough to capture all the natural variability in the state, some experts say. “Natural background phosphorus concentrations can differ by an order of magnitude for adjacent springs or even within a 100-meter reach of a stream in Florida,” said Jan Stevenson, an environmental scientist at Michigan State University (East Lansing). EPA is doing the best it can, “but Florida has to be the most difficult state for developing nutrient criteria, because it has a complex mix of rock strata, and waters from these chemically diverse ecological formations can have highly different water chemistries,” he said. There is a real risk that a region’s nutrient criteria could overprotect sites with naturally high background levels of nutrients while putting at risk nearby sites with low background levels, he said.

“There is a concern that EPA may apply a single model to calculate nutrient criteria for all of Florida’s estuaries,” said Holly Greening, director of the Tampa Bay National Estuary Program. “That won’t work, because our estuaries have very different systems,” she said. Large and deep, Tampa Bay is just north of Sarasota Bay, a small lagoon system. Each bay has been intensively studied, and the models used in one are not transferable to the other, she said.

Greening also is worried that a single criterion to cover an entire bay won’t address the variety of unique habitats within the bay. Nutrient targets that will keep the open parts of the bay clear enough to support seagrass will be too low to provide the kind of algal growth required by juvenile fish in tidal creeks of Tampa Bay, she said.

The uncertainty of the models used to calculate nutrient criteria is another complicating factor, Downing said. For instance, in Iowa, an average concentration of 35 ppb phosphorus will protect most lakes from adverse impacts. But there is a measurable probability that it may not be stringent enough or could be too stringent. “In some lakes, natural background levels can vary substantially among years, depending on weather and other watershed conditions,” Downing said.

This kind of uncertainty will drive EPA to err on the side of caution and set nutrient criteria on the low side to be sure of avoiding overenrichment, Clark said. At the same time, the regulated community will likely err on the side of caution to make sure they meet nutrient criteria with a high degree of certainty. “The resulting treatment requirements … will likely be extremely costly in an effort to prevent what may be a minimal combined risk,” Clark said.


Moving forward
“We should state nutrient criteria in a probabilistic way to address uncertainty,” Downing said. For instance, after new research showed that clean lake water generates $124,000/ha•yr ($50,000/ac•yr) in wealth for the state, the Iowa Legislature passed a lake restoration law. The law mandates that lakes must attain a clarity depth of 1.5 m as gauged by a Secchi disk, a device that measures water transparency. However, the law makes room for uncertainty by saying the criterion must be met 50% of the time, Downing said.

The two-tiered assessment system that the Florida Department of Environmental Protection had planned to include in its nutrient criteria rule is a good way to handle uncertainty and variability in the biological response of a system to nutrient levels, Clark said. In two-tiered systems, if a waterbody exceeded the nutrient numeric standard, it would be followed up by a biological assessment to confirm that nutrients were indeed leading to impacts to biological integrity. Another alternative in cases where waterbodies have natural background concentrations exceeding the nutrient criteria level is to apply site-specific alternative criteria, Clark said. Site-specific standards can be more or less stringent than the state standard as long as they protect biotic integrity, he said.

“We have to find the courage to set nutrient criteria, because when we need to control nutrients, we will find creative ways to fix things,” Downing said.


Janet Pelley, WE&T

Clicking through the World Wide Web

Utilities leap into social networking with positive results

Water and wastewater utilities are not usually considered the hippest of industries. Nor does social networking typically come to mind when one thinks of these operations, but during the past few years, some have begun posting messages on Facebook and Twitter, uploading videos on YouTube, and creating blogs about their organizations to help better relate to and reach out to customers.

Virginia Beach (Va.) Public Utilities, which offers water and wastewater services to Virginia Beach residents, launched its Facebook page in May during National Drinking Water Week.

“It was just a logical place for us to be, because our customers are already there,” said Katie Rider, media and communications coordinator at Virginia Beach Public Utilities and the utility’s Facebook page administrator. “We were a little hesitant at first to jump into it. We hesitated about how much it would take to manage it, and we wondered if it was a lot more than we would want to do.”

But so far, it has not been nearly as time-consuming as they thought.

“I wish we had done it sooner,” Rider said. “We were a little late coming to the table.”

Ely Teragli, public information specialist at Clean Water Services (CWS; Hillsboro, Ore.), said there were a lot of reasons why her utility started two Twitter pages last year — CleanWaterNews and RiverRanger, which focuses on the Tualatin River — but the biggest reason was “we wanted to keep current with all the ways to communicate with customers.”

CWS e-mails newsletters and mails printed newsletters to customers’ homes, but “we wanted to incorporate social networking into the overall media plan,” Teragli said.

Liza Young, community relations specialist at Loudoun Water (Ashburn, Va.), said social networking not only enables her utility to communicate with customers, it enables customers to better communicate with the utility.

“It offers a more personal form of interaction,” Young explained. “Usually, we don’t hear from them unless they call customer service with complaints or come to events.”

Social networking also has offered immediacy, said Tony Benson, communications coordinator for Rochester (Minn.) Public Utilities, which provides electricity to 47,000 customers and water to 35,000 customers.

“For example, if a water reservoir ran dry — though let’s hope that never happens — or if there is a water main break, we can let [our customers] know immediately what’s going on and what we’re doing to take care of it,” Benson said. “Also, much of the local media follows our Twitter feed.”

Posting information on Twitter lets the public and the media know what’s going on simultaneously, Benson said.


Getting started
The issues water and wastewater utilities face when setting up social networking sites can vary, but one of the biggest obstacles can be getting the rest of the company on board with plans to enter the Web 2.0 realm.

Rider said she was a little worried about whether the director and business division manager at Virginia Beach Public Utilities would buy into the idea. “But they were immediately responsive and said if I thought that’s where our utility needed to be, they were willing to do it,” she said.

Lee Ann Hartmann, public information specialist at the Newport News (Va.) Waterworks, said she got full support from her director and upper-level management to start a Facebook page for the utility, but they had some questions and concerns prior to the launch.

“They wanted to know if the page would be subject to [the Freedom of Information Act],” Hartmann said. “‘Would we be required to keep a record of posts?’”

Hartmann said she discovered that the site is subject to the act and subsequently keeps PDF copies of all its Facebook posts.

A few other questions utilities may have to address before setting up social networking sites are

  • Who in the organization is responsible for writing the posts?
  • How often will posts be made?
  • What will be the tone of the site?
  • What type of information should be posted?
  • What comment-policing mechanisms will be used on the site?

Young said she posts to Loudoun Water’s Facebook page two to three times per week, but a customer service representative volunteered to post tweets on the utility’s Twitter page. He posts between three times a day and three times a week.

“We try to coordinate what information we post so we aren’t repeating the same thing,” Young said.

Eric Isaacson, a spokesman at Colorado Springs (Colo.) Utilities, said that even though everyone in the utility’s corporate communications division has the ability to post on its social networking sites, he usually posts all the material. He writes two to three posts a week on the company’s Re:Sources blog and tries to write at least one Facebook and Twitter post daily. The utility also has its own YouTube channel where 50 videos have been uploaded. The videos cover a range of topics from water and energy efficiency to community involvement. Isaacson said some of the videos are made in-house, and some are outsourced to a production agency.

After site administrators determine who should post and how often, they may grapple over what information should be posted. Preferences vary, but there are some rules of thumb.

“When you talk about Twitter, some work by the 33–33–33 rule,” Teragli said. “Thirty-three percent is made up of your own information, 33% are retweets, and the remaining 33% is where you solicit information or promote conversation.”

Some administrators try to ensure that they focus on certain topics. To do this, Hartmann said she keeps a list of messages that she and others in the organization want to promote, such as new billing options. She said she also wants to make sure the Facebook page stays current. For instance, during the summer, she did frequent posts about the ongoing drought in Virginia.

Isaacson said he pulls information from a variety of sources, such as staff meetings or weekly “new media” meetings where corporate communications staff members discuss questions frequently asked by local media and messages the company is trying to promote. He said he also checks the community calendar and tries to see what is happening at the moment.

But no matter what is posted, most administrators agreed the key is to always keep the tone light.

“You have to stay away from ‘utility speak,’” Isaacson said.

To make sites more enjoyable, administrators also may find themselves discussing unconventional topics.

“One week, I posted an article that talked about how jellyfish are 90% water,” Rider said. She admitted that the topic was only vaguely related to water utilities, but more importantly, “I just thought it was interesting and funny,” she said.

“With utilities, ‘funny’ isn’t necessarily the first thing that comes to mind,” Teragli explained, “but you have to consider the medium. It’s very casual.”

Even if the tone is enjoyable and casual, site administrators said commenters are not allowed to cross the line between fun and poor taste.

Benson ensures that all comments posted on Rochester Public Utilities blog are appropriate by having them delivered to his e-mail account before approving them to appear online. After he approves the comment, readers can see it on the blog.

Few have had to remove comments from their sites, but Hartmann said she could remember one instance in which an expletive-filled comment had to be taken down. She said she made a full disclosure online, explaining to the other users why the post was taken down and how the concerns of the person who posted would be addressed. (Hartmann said she apologized to the poster on behalf of the utility. He also was given an e-mail address and the number to contact the customer service manager.)

“People are allowed to be mean,” Hartmann said. “They’re even allowed to call us names, but if it starts getting too rough, then we have to take it down.”

Rider said Virginia Beach Public Utilities also has standards in place and terms of use listed on its Facebook site for people who post, but she emphasized that she will not take down negative comments just because they are negative.

“People may doubt the credibility of your site if you start deleting all negative comments,” Rider said.

If you build it, they (might) come
After the blog, Facebook, and Twitter pages are up and running, site administrators will encounter their next challenge: getting and keeping visitors.

“When we launched our site during Drinking Water Week, we had big numbers, but it started to taper off a little after that,” Rider said. “It’s slowly starting to grow again.”

Hartmann said the number of people who “like” the Newport News Waterworks Facebook page also has grown very slowly. (At press time, it was 206 people.) The utility promotes the Facebook page on its home page, in the customer newsletter, billing inserts, newspaper blurbs, and on the local government-access television channel, but it’s been an uphill battle.

“But we’re not discouraged,” Hartmann said. “In fact, we’re encouraged because some of the conversation we’ve had with customers via postings have been very positive.”

Tracking sites’ popularity can be challenging.

“We have different ways of judging it, either through our number of followers or retweeting,” Teragli said. “Right now, our CleanWaterNews Twitter account has 859 followers, and our RiverRanger account has 219 followers.”

But Teragli warned that even though these data are useful, they are not the only things that matter. Though there are online programs like Google Analytics that allow site administrators to track Web traffic and Google Alerts to show how often a link on a blog is mentioned, these numbers do not paint the whole picture and cannot tell whether a site is really successful.

“You have to think in broader terms,” Teragli said. “I wouldn’t judge a marketing campaign from just the numbers, so I wouldn’t do that for this either.”

Several of those interviewed said site administrators also have to consider how involved people are on the site.

“We’re getting positive feedback from the fans,” Young said. “I used to be more concerned with how many people were signing up for the page, but now I’m more focused on interaction. I’m trying a little harder to get them to interact with us.”

Utilities said that ultimately the goal is not to gather as many Twitter followers as Hollywood actor Ashton Kutcher (at last count, he had more than 6.3 million followers) or have one of the most popular Facebook pages on the Web.

“We just want customers to realize this is a good resource,” Hartmann said.

LaShell Stratton–Childers, WE&T

Continue the social media conversation with others facing the same challenges at and

Ready when nature strikes

Are wastewater utility preparations lagging behind in disaster preparedness?

Water and wastewater utilities are vulnerable to wind, flood, earthquake, and other natural disasters. According to the 2009 document “All-Hazard Consequence Management Plan for the Water Sector” compiled by the U.S. Environmental Protection Agency (EPA), other federal agencies, and utilities, natural disasters can lead to loss of power, communications, and supervisory control and data acquisition systems, as well as water contamination and service disruption. To ensure minimal system damage and limit delay in getting back on-line, water utilities must understand their vulnerabilities, make plans to minimize system impacts, develop emergency response plans, and train staff.

Training, free tools, and federal funding are available. There also are a number of management examples from which to learn. In 2006, only three states had Water and Wastewater Agency Response Network (WARN) systems, but today there are programs in 47 states. Utility assistance networks provide training and can shorten recovery time from disasters, according to experts and real-world examples. These networks have been activated in eight recent major disasters and numerous small instances, said Kevin Morley, security and preparedness program manager at the American Water Works Association (Denver), which developed WARN with EPA funding.

However, despite a decade of preparing for disaster, “there have been challenges getting wastewater folks to the table,” Morley said.

Emergency response planning
More water utilities may be preparing for natural disasters because the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 required all water utilities serving more than 3300 residents to submit to EPA vulnerability assessments — the initial step in preparing hazard mitigation plans. Wastewater utilities have not been tasked federally to do this; however, many states require wastewater utilities to develop emergency response plans.

The city of Albany, Ore., embarked on hazard mitigation planning following the passage of the Disaster Mitigation Act of 2000. In 2003, the U.S. Department of Homeland Security’s Federal Emergency Management Agency (FEMA) provided Albany with almost $375,000 in predisaster mitigation grant funds for planning, and the University of Oregon (Eugene) offered technical assistance.

It took 150 hours to develop the city’s comprehensive 2005 hazard mitigation plan and 120 hours for personnel to prepare reports. The 2010 update required 120 hours of staff time to prepare and 30 hours for the city’s committees to review. During that time, the steering committee met twice annually to review progress on action items for each hazard outlined in the vulnerability assessment and posted results on the city Web site.

The greatest challenge in developing mitigation plans is getting individuals to understand it’s not just another plan that takes a lot of time to develop but then sits on the shelf, said Darrel Tedisch, emergency management specialist with the city of Albany.


Water system failures
Catastrophic water service disruption caused by various disasters can lead to power outages at facilities, distribution systems that suffer broken pipes and malfunctioning pumps, and water contamination.

In Albany, due to its layout and hazard risks, water system vulnerability has been greatly reduced with the addition of a second water plant and numerous costly seismic updates. The city staff also advised that routine scheduled maintenance reduces water plant failures, and regular monitoring at water intake locations helps reduce risk of contamination problems.

Despite this preparation, the potential for widespread failure still exists, according to city staff. For example, in Albany, some areas have only one feeder source for water.

“Distribution is an area of concern,” said Richard Weisman, acting team leader for the emergency response team in the Water Sector Division of the EPA Office of Water.

System failures would have a mild to severe impact on Albany residents, businesses, and industrial plants. Firefighters and the city itself may need to tap reservoirs during major power failures, because no backup power is available at either of the treatment sites. Adding generators would eliminate the power-failure threat.

Albany’s vulnerabilities also include source water concerns. While a joint water venture has provided a second source for water, water conveyed from the Santiam River is highly vulnerable to contamination from stormwater runoff. According to EPA, more frequent flooding due to climate change also could cause increased wastewater overflow discharges, and this should be a concern for wastewater utilities.

“The historic record could be unreliable for the future of overflows,” said David Travers, director of EPA’s Water Security Division.

Albany plans to conduct a vulnerability analysis of its wastewater collection system during the next 2 to 5 years.


Stress-free training
Once a system outlines its vulnerabilities and prepares to mitigate hazards, it also must train staff on how to respond to natural disasters to help improve a utility’s ability to respond effectively and get affected systems back on-line quickly.

It’s crucial to “practice, test, and improve emergency response planning procedures in a stress-free environment,” Weisman said.

To aid utilities in training their staff, EPA recently updated its free guide, Emergency Response Tabletop Exercises for Drinking Water and Wastewater Systems, which is available on CD. More than 3000 copies of this guide have been released. EPA also worked with FEMA to modify the National Incident Management System (NIMS) and Incident Command System (ICS) courses and offers tailored classes to the water sector.

NIMS and ICS provide a consistent framework, Weisman said. If utilities have a better understanding of ICS and NIMS, they’re going to communicate in a clear and effective manner, he said.

Travers added that during disasters, such as the Midwest flooding in 2008, utilities “have relied on their NIMS/ICS training.”

Neither FEMA nor EPA has compiled data on the number of water-sector utilities that have gone through the training. However, Travers said the agency has “trained close to 10,000 utilities” since the program began. In 2010, EPA trained at 320 facilities, reached more than 300 through WaterISAC (Washington, D.C.), and performed practice exercises with various state WARN programs. Several more utilities trained online through FEMA’s Web site, Travers said.

Weisman also noted that becoming NIMS-certified makes a utility eligible for Department of Homeland Security funding. More than $3 billion was available in 2009.

EPA’s on-location training sessions last 1 to 2 days, depending on the number of courses offered. Staff must pass an online test to achieve certification.


Utilities helping utilities
Prepared and well-trained utility staff may still need more hands when disaster strikes. This has led many to participate in WARN programs. Clarence Warnstaff, chairman of the Virginia WARN Committee and business development manager for water programs at Michael Baker Corp. (Moon Township, Pa.), said Virginia WARN’s 19 signers represent the state’s largest utilities. In the year since being established, “half the state is covered, but there is still a lot of work to do,” he said.

Travers said the benefits of the WARN program were illustrated in March 2008. After a substantial salmonella outbreak in Alamosa, Colo., — the state’s worst outbreak in 20 years — a number of Colorado WARN utilities got together to manage sampling, flushing, and disinfection of the afflicted water system.

Once called, partnering utilities had “boots on the ground in 24 hours,” Morley said.

Alamosa was not a participant in the network at the time and was not yet aware of the newer program, said Don Koskelin, Alamosa public works director and assistant city manager.

In the 10 weeks following the Alamosa outbreak, CoWARN membership increased from 33 to 61 utilities, according to the American Water Works Association 2008 white paper “Economic Benefits of WARN.”

Without CoWARN, “things would have been much worse,” Koskelin said. “It was vital to addressing the situation we were faced with,” because, as a small utility, Alamosa does not have the personnel required to develop and execute an effective response plan for a situation on the order of the outbreak’s magnitude, he added.

Often, small utilities hesitate to sign mutual-aid agreements and participate in WARN programs because they think they can’t afford it, Morley said. “They could also be under the illusion they can’t help anybody,” he said.

However, Ken Pollock, superintendent of water treatment at Denver Water, a CoWARN member that responded to the Alamosa outbreak with staff, supplies, and financing, noted how important it is for large utilities to connect with smaller ones through the program.

At some point, if Denver water needed assistance, it could borrow people from smaller utilities who have experience, Pollock said. While Denver spent thousands of dollars on labor, staff accommodations, and use of equipment in responding, it asked Alamosa to reimburse only $4600 for consumable supplies.

Many natural disasters causing large water system breaches were ultimately self-contained. “There were a lot of dress rehearsals,” Morley said. He agreed that larger water utilities at times will need to tap outside staff.

Many of the experts interviewed said smaller utilities perhaps stand to gain the most benefit. There is no cost to sign mutual-aid agreements — other than staff time to perform due diligence, there is no obligation to respond to requests, and training is free.

The onus is on small utilities to realize before disaster strikes that “these are the rules of the sandbox,” Morley said. “Ideally, you don’t want to be signing this on the hood of a truck,” he said.

— Andrea Fox , WE&T

© 2011 Water Environment Federation. All rights reserved.