Turbidity Curtain (Floating Basin Boom)

Result of inappropriate boom installation

Result of inappropriate boom application – wasteful and harmful, not helpful

I was recently asked to weigh in on regulatory requirements and the use of turbidity curtains or floating basin boomI passed along the following –

 

A few observations related to experience with turbidity curtains over the last 20 years or so…

• Turbidity curtains can keep turbid water separated from clear water under appropriate conditions.

• Turbidity curtains can minimize the migration of sediment from one area of still water to another.

• When turbidity curtains work, sediment is deposited on the bottom of US waters, with no good way to retrieve it.

• Sediment cannot be effectively removed from waters flowing with much velocity.

• Turbidity curtains are not permeable and will act as a dam, until the force of water exceeds the capacity of the anchoring.

• Where there is current, or fluctuation in water level to any degree, adequate anchoring to maintain performance is nearly impossible.

• Turbidity curtains are expensive compared to the benefits received.

• Many stormwater professionals, regulators, environmentalists, contractors, and the general public are comforted by seeing turbidity curtains installed. Others, including myself, recognize the misplaced confidence and sometimes harmful impacts of the boom.

 

I encourage designers, contractors and other professionals to think hard about the purpose and expected performance of the turbidity curtain before specifying or installing one.

 

Result of appropriate boom application - sediment still captured in US Waters

Result of appropriate boom application – sediment still captured in US Waters

Some considerations:

• Is the boom being used simply as a redundant feature? (we should never intentionally capture upland sediment in our US waters)

• Is the boom being used to minimize the migration of sediment that existed in the water prior to disturbance?

• Is the water body completely still with very little velocity or anticipated change in level?

• If effective, will the ultimate removal of the boom and any captured sediment do more harm than good?

• Is the turbidity curtain needed for image and appearance? (if so, are conversation and education in order rather than scarce resources spent on an ineffective BMP?)

 

Your experiences and thoughts?

Good Enough

Over the holidays my wife and I were painting my youngest daughter’s room and struck up a conversation about standards and quality.

We noticed that the top of the window and door trim had not been painted when the house was built. We are both ok with that but I’m guessing my Dad may not have been. I’m guessing that if he were doing the painting, the unseen parts of the trim would have been just as presentable as the most visible parts. I don’t know if that is a generational thing (many would say it is), or if its a personality thing, or simply a resource and priority-based decision that we all must make.

I’ve been in Washington DC this week and have found brief pockets of time to walk about some. I have paid particularly close attention to hidden details in building architecture and in art this trip. There are monuments and sculptures on every corner. I also visited the National Gallery of Art. The paintings were amazing – from Van Gogh to Monet to Gerome; from abstract to modest to detailed beyond my imagination.

BMP as Art: gargoyles were initially added to architecture to route stormwater away from exterior walls.

BMP as Art: gargoyles were initially added to architecture to route stormwater away from exterior walls.

Many artists and craftsmen spent many hours and much effort designing, carving, painting, and shaping details that most of the works’ admirers would never see or appreciate.

So back to the question of quality and what should be considered good enough (I also need to tie this to stormwater somehow). I think there are at least three areas that need to be considered as we determine what level of quality is good enough – function, the consumer, and resources.

Function: will my work serve its intended purpose? (is it truly protective of water quality?)
Consumer: whom do we work for? (other than the client, who else might be counting on us?)
Resources: do I have the time, money, materials, craftsmanship to do this right? (why not? the client is paying you exactly what you asked for during the bidding process. Right?)

Checking the box… or making beneficial art?

Doing what is necessary every time… or only when someone can see you?

Barely meeting expectations set by your winning low bid… or surpising everyone with your innovation and attention to detail?

We don’t get to decide if our art is valuable. That’s up to those who experience it.

 

Bonus: photo and close ups of View of Medinet El-Fayoum by Jean-Leon Gerome, oil on panel c.1868-1870

(Click on, then zoom into and around the images.  The level of detail is amazing, even with the less than perfect photography.)

The Painting

The Painting

zoomed in to the bridge

Bridge Close up

Water close up

Water close up

 

 

 

“Too thick to drink, too thin to plow.”

That’s how 19th century settlers described the water flowing in the Colorado River as it made it’s way through the desert and canyons of the Southwest.

The Colorado is easily one of the siltiest rivers in the world. Prior to the building of Glen Canyon Dam in 1963 over a half a million tons of sediment was carried through the Grand Canyon every day (yes, every 24 hours). For those of us in the eastern US, one cubic foot of water in the Colorado is 17 times more silt-laden than the same volume of water in what we call “the Muddy Mississippi.”

I have heard reasoning and excuses using the Grand Canyon and Colorado as the basis for why we shouldn’t try so hard to protect water quality in other areas.  It goes something like this – “…erosion is a natural process.  If we didn’t have erosion and sediment, we wouldn’t have the Grand Canyon, the Little River Canyon (featured in the email notice to subscribers), or the marshes of Louisiana, …or (fill in the blank with any other natural feature that was created by water over thousands of years).” I have been confounded by the level of authority and influence of those who like to make such statements.

While the statements may be correct in the right context, when comparing the potential stream and habitat impacts of our work and the artificial erosion and sedimentation that can and sometimes does happen, there is no comparison. The language can make the most honored and respected of us look downright silly.

Again, context is the key. One thing I have observed over the last twenty years is that streams (and nature in general) are pretty flexible. They can be polluted, straightened, boxed, and impacted beyond imaginable repair (natural impacts can be pretty ugly also), and over time, if the injury ends and the stream is left alone, sooner or later it will regain its former purpose and once again become healthy.  The lower Colorado and its ecology is dependent on it’s sediment load, so much so that reducing that load through damming was actually detrimental to its overall health. Streams in my area (Southeast US) have a different set of needs to remain healthy. Their health thrives with a lower sediment load which is “more natural” here.

Whether we are adding tons of sediment per year or removing it; adding runoff or keeping it onsite; increasing the rate of discharge or decreasing it; we have a responsibility to understand as best we can the consequences of our actions. Not much happens in a vacuum and not many alterations in nature go unnoticed.

At the very least, we need to try our best to keep ourselves and our clients from sounding downright silly. When decisions are being made based on misinformation or convenient myths, someone should call it for what it is.  I’m thinking that’s us.

Myth: 1.) a widely held but false belief or idea; 2.) a traditional story, especially one concerning the early history of a people or explaining some natural or social phenomenon, and typically involving supernatural beings or events.

 

Behind the scenes: The Colorado River sediment facts came from an excellent book I’m reading called The Emerald Mile. I’m loving the book and can’t wait for future inspiration and knowledge.

 

 

>90% Sediment Yield Reduction in 3 Easy Steps

Step 1: Delay disturbance.

Step 2: Limit disturbance.

Step 3: Once disturbed, cover it up quickly.

Covered Slope

Covered Slope

Sediment yield is measured in tons per acre per year. These units alone tell us that a reduction in exposed area or a reduction in duration of exposure can each have a direct effect on the mass of sediment produced. Can we clear less than we did last time? Can we wait a little longer before clearing? Can we get back to stabilized state more quickly?

Different sources provide varying numbers for the capacity for ground cover to minimize erosion and subsequent sediment yield. Depending on the type of cover, a conservative compilation of estimates is above 90%. RUSLE C factors also vary. USDA/NRCS numbers provide cover management factors in the range of 0.02 to 0.25, reflecting soil loss reductions of 75 to 98 percent, given all other conditions being equal.

The numbers seem to be incredible. If we said out loud to regulators, riverkeepers, and the general public that we could reduce the quantity of the most significant pollutant in construction runoff by 98%, what do you think the reaction would be? Is that something you could say convincingly?

The next question is, why are we not doing more to promote this super-effective BMP? Why do we continue to argue over 3 or 4 theoretical percentage points of reduction effectiveness for sediment control BMPs? I don’t know of a single TMDL for siltation that requires a 98% reduction in sediment. I wonder sometimes if we simply don’t trust the research that brought us these theoretical numbers.

I agree with Gavin Schmidt, who reflected on modeling in his TedTalk.  He said, “Models are not right or wrong; they’re always wrong. They’re always approximations.” He went on to say, “if we had observations of the future, we obviously would trust them more than models, but unfortunately, observations of the future are not available at this time.”

So what do we do with the results of our models and prediction tools? I say, use them to the limits of their trustworthiness. Use them for comparisons of different scenarios. Use them as general estimations of what might happen, given selected ideal conditions. Put some cushion in there, sure. But take what we can to improve our work.

Side-By-Side

Side-By-Side

I was on a project recently where I was able to see directly and clearly, in a side-by-side comparison, the benefits of cover. I saw the general results of what I could have modeled earlier.

Remnants of temporary mulch were still visible in the emerging temporary vegetation on a slope that had been cleared and grubbed several weeks earlier. A few days earlier, topsoil was stripped on a part of the slope in preparation for upcoming excavation operations. The project experienced a just less-than 2-year frequency storm before I arrived. Checks, sumps, and a sediment basin at the foot of the slope were loaded from deposition of heavy sediment. The slope was significantly rilled.

To get better footing, I walked in the rills up and across the slope over to the part of the slope where mulch and vegetation remained. The contrast between the two treatments of the same slope was remarkable. Where mulch and vegetation stood, there were hardly any rills. Where the topsoil had been stripped just feet away: a slippery, muddy, gullied-up mess with long channels where soil used to be.

Was the loss in the stripped area 98% greater that of the mulched and vegetated area? Probably not. But if the project team had kept in mind at least the theoretical effects of stripping the slope, would they have waited to strip until after the storm? Possibly.

Stripped Slope

Stripped Slope

What is the use of having developed a science well enough to make predictions, if, in the end, all we’re willing to do is sit around and wait for them to come true? - Sherwood Rowland

 

I have shared the Gavin Schmidt and Sherwood Rowland quotes before. The experience of seeing the stark contrast in soil loss with my own eyes presented a good opportunity to share them again. Comment here if you’d like, but I would prefer to keep the conversation in the EnviroCert discussion groups on LinkedIn.

 

 

 

My 2014 Stormwater Influencers

It’s easy to start a list of those who have influenced my work this year. Many of you are on that list. When we think about those who made us better and those who caused us to be more effective, we have a tendency to drift toward the more technical elements of our work. We focus on measureable things. Some elements of stormwater can be measured. There are rules and regulations; there is modeling and equation-solving; there are technical terms and concepts.

But most of our world isn’t easily specified or measured. When we are working at our best, there is innovation, creativity, critical thinking, art, and there are also people involved. I am thankful for the talent and generosity of all of those who have helped me to grow technically this year. But I am also thankful for those less-technical mentors and influencers. Most on my list do not know me, but each has made a profound difference in the way I approach technical topics such as stormwater.

I can think of at least one significant stormwater-related lesson each them have taught me. I have started a list below beginning with experts and examples that are also accessible and available for your inspiration. As you are getting better, don’t forget that your technical world could benefit from some less-than-technical influence. How we carry ourselves, how we think, and how we treat people matter, even as we carry out our technical work. 

Some of my non-technical influencers (links are to some of my favorite related works):

Seth Godin, a marketing guy;
Guy Kawasaki, an evangelist (in the business sense);
Dr. Henry Cloud, a psychologist;
Dr. John Maxwell, a leadership author;
Simon Sinek, someone who asks WHY before what or how;
Andy Stanley; a preacher;
Dan Pink, an observer of human behavior;
Dave Ramsey, a teacher;
Jesus Christ, an example of one who led as a servant, gave unearned grace, and intentionally developed a perspective and empathy for others around him.

 

Thank you for sharing 2014 with me. Here’s to a productive, effective, exciting, and improving world of surface water quality in 2015.

Merry Christmas.

Barry

Showing Up

I’m a proponent of knowing our why, or purpose, then working in alignment with it.  It’s an effective approach to business and to life, and it can be applied regardless of what we happen to be working on.  If we know why we’re doing it, our work is likely to be more clear, more effective and more productive.  When our effort involves other people, and most of it does, we must also consider the why of those we need to help us achieve our objectives.

I didn’t make it to our community Christmas parade this year. I attended a wrestling parent meeting instead (meeting for parents of wrestlers, not one for wrestling parents). I must say, I was a bit disappointed when my wife and youngest daughter went to the parade without me. I was also disappointed to later find out that it wasn’t the parade we grew up with. The local dance studio didn’t dance, they just walked together in a mob. The local politicians didn’t throw candy, they just rode in vehicles with campaign signs stuck to the side. Two local radio stations had vehicles with loud speakers, but instead of playing Christmas music, they simply played the radio, complete with commercials.

I’m sure these folks and others had reasons for showing up. Some may have wanted to bring awareness to their cause or business; others may have been to support the community by paying the float fee as a donation (which could have been done without wasting everyone’s time); or marching in the parade may just be what they do – it’s what they’ve “always done.”

But many seemed to have missed out on one huge point: the parade isn’t about them. It’s about us. Sure, they can certainly gain personal benefit as a byproduct of doing good. But we didn’t show up to support them.  We came to see a parade.

Why do you show up? Is it simply to be seen, or paid? Is it just what you do every day? Or, are you showing up to give us what we paid for? Our presence, our interest, our time, and other support for your cause is always less-than-guaranteed. I’m not sure why anyone would risk it.

We get to choose what we do today. We decide where we do it and how we do it. It’s hard to make those decisions without knowing the why.

The skills of a leader (or good parade coordinator) can also help. A simple reminder with the invitation might teach or help us willing servants to remember why you wanted us to help you in the first place. A quick poll of your patrons or stakeholders might reveal a service gap that you were not aware of. But leader, you above all others, have to remember that you also must decide to show up. Not for your sake, but for ours.

THE best management practice

Communication is by far the most effective, most economical, and most efficient BMP we have available to us. Like other BMPs, we are obligated to implement it to the maximum extent practicable using best available technology. Use of best practices is expected as we plan, as we design, and as we build. We also have obligations to our profession, our clients, and to ourselves to use best practices as we develop professionally.

We are living in an amazing age of technological advances, particularly in the realm of communication. We have never had more access and opportunity for connection as we do right now. With or without our desire, we are connected socially, economically, and technologically to millions of people around the world. Even our niche profession is so connected that it is difficult to keep up.

One of the best formats that I have found to stay in touch with the advancement of our profession is LinkedIn. Some say LinkedIn is Facebook for professionals. I would like to think it is much better than that, but I’m not a Facebook user. I have personally made valuable connections to people, to information, to data, to technology, and to best practices through LinkedIn. Some of those connections came through updates posted by my network, many others came from conversations within LinkedIn discussion groups.

I serve on the EnviroCert International Board of Directors. I am also the chair of a newly forming Program Development Committee for the organization. Rob Anderson, Board Chairman, has described this committee as being “… a think-tank group consisting of the best technical and leadership minds in the organization to promote and direct the future of certifications…”  Our vision is to increase the value of and the value to certified stormwater professionals.  We will do this by focusing on leadership, relevance, and connection.

We have decided that one of the very best tools for advancing these three focus areas is LinkedIn discussion groups. EnviroCert will lead the stormwater profession by making available a platform for the very best minds in the industry to share very best practices with others seeking knowledge and information. To ensure the value of certified professionals, the committee will use these discussion groups as a place to monitor the pulse of our profession and the needs of society. The committee will inform other committees and the Board of gaps between society’s needs and certification standards, and make recommendations for filling these gaps. And through these discussion groups professionals will become connected to best technology and practices, to EnviroCert and its communities of practice, and to each other.InBug-60px-R

There are currently four communities of practice related to stormwater runoff represented within and by EnviroCert:

pollutant sources, transport, and treatment, represented by Certified Professionals in Water Quality (CPSWQ);

municipal, represented by Certified Municipal Separate Storm Sewer System Specialists (CMS4S); and

land disturbance, represented by Certified Professionals in Erosion and sediment Control (CPESC);

inspection, represented by Certified Erosion and Sediment and Stormwater inspectors (CESSWI).

We have created a discussion group for each of the four communities of practice. All are subgroups of a common discussion group for EnviroCert International. Due to LinkedIn rules, one must be a member of a parent group in order to be a member of one of its subgroups.

These discussion groups are created for all stormwater professionals, certified or not.

So here is my request -

  • join LinkedIn
  • join the EnviroCert discussion group
  • join one or all of the subgroups (CPSWQ, CMS4S, CPESC, and CESSWI)
  • adjust your settings for each group
    • click on the i (information and settings) at the upper right of the page
    • for your community of practice group and the EnviroCert Group:
      • check – send me an email for each new discussion.
      • uncheck – send me a digest of activity (this might overload you with information)
  • look over the rules (information and settings button again, then rules link)
    • most important rules – Bring value. Bring ideas. Be professional. Be generous. Be nice.
  • connect with me, EnviroCert staff and Board Directors, and other stormwater professionals inside and outside of your community of practice
  • “like” the first post in each group you join (this is one way you can help share news of the new groups)
  • share what’s new and exciting in your world with your profession

Comment here if you’d like, but I would rather hear what you think in group discussions.  Thanks.

 

Stormwater in the Mainstream November 2014

I hope you are having a wonderful Thanksgiving weekend.

Foremost in the mainstream news this month was the ending of the comment period for a proposal aimed at clarifying the definition of Waters of the US.  The mainstream news was a bit disappointing in relaying the facts.  But then again, so were the most vocal of those quoted.  I have also included a few articles on apparent effects of undiluted urban runoff on certain fish.

Enjoy this month’s Stormwater in the Mainstream brought to you by StormwaterTools.com and Google News.

EPA’s Waters of the US proposal met with controversy

KPVI News 6-
POCATELLO, ID. — This week the Pocatello Chubbuck Chamber of Commerce joined with more than 350 organizations in protesting the …

EPA seeks to clarify Clean Water Act’s scope

Poughkeepsie Journal-
EPA officials say the proposed rule is designed to clarify which bodies of water are subject to the agency’s oversight under the Clean Water Act.

See realtime coverage

Death by Dirty Water: Storm Runoff a Risk for Fish

ABC News  
With pollution from industrial pipes closely regulated, cities and states are more often tackling stormwater runoff that results from everyday activities: oils from leaky cars, pesticides from lawns and other pollutants that wash off roads and

Filtering rain runoff reduces its threat to salmon, study suggests

The Seattle Times  -
Stormwater runoff that results from everyday activities – oils from leaky cars, pesticides from lawns and other pollutants – killed fish within four hours in a recent study.

Salisbury may offer stormwater fee discounts

Delmarva Daily Times  
Instead, it offers a discount of up to 75 percent of the fee to property owners who can prove that their private stormwater systems meet the highest standards for curbing runoff-related pollution. The rate to be charged won’t be established until a

Conowingo owner may lose permit over water quality

Delmarva Daily Times  
Michael Helfrich, of Lower Susquehanna Riverkeeper, is pictured at the Conowingo Dam. He is raising concern that silt and nutrient pollution attached to the sediment buildup at the dam could undermine restoration effort of the Chesapeake Bay.

Treating runoff on State Street

Bellingham Herald  
The city is removing 19 street trees on State Street between Central Street and East Bay Drive as part of a larger project to improve treatment of stormwater runoff that currently drains untreated into Moxlie Creek, and eventually flows into East Bay

Increased Stormwater Fee Proposed in Harrisonburg

WHSV  
As part of the Environmental Protection Agency’s Clean Water Act, the federal government requires every community, including those right here in the Valley, to come up with a way to manage stormwater runoff in an effort to maintain pollution and

Mayor Bach to ask City Council for help in storm water issue

KRDO  
Last week, voters turned down a ballot measure that would raise money to combat the city’s storm water issues. Bach said he plans to ask the City Council to put a measure on April’s ballot, that would ask voters to approve new bonds to replace bonds

Churches, nonprofits win battle over Downers Grove stormwater fee

Chicago Tribune  
“My hope is that we will find a way to make sure that we don’t reduce our commitment to solving the stormwater problems in Downers Grove,” Hose said.

Michiana Stormwater Partnership installing signs across Michiana

ABC 57 News  -
One group in Michiana, the Michiana Stormwater Partnership, wants to change that and educate the public on how they can help to keep our waterways clean and free of pollutants.

MP is angry at erosion ‘saga’

Nelson Mail  
West Coast Tasman MP Damien O’Connor says he has little faith in Tasman District Council’s ability to manage the proposed Waimea dam, given what he sees as its “inability” to manage an erosion issue at Pakawau, that residents are prepared to pay to …

Close Clean Water Act loophole

Baltimore Sun  -
But far too many of the streams and wetlands that flow into the Chesapeake, along with more than half of the streams that crisscross our state, do not have guaranteed protections under the Clean Water Act. That means developers could build over our …

Volume Of Stormwater Damaging

Hartford Courant  - ‎18 hours ago‎
It correctly noted serious water quality impairment owing to stormwater, and new state efforts to curtail these contaminants.

New York Plants Curbside Gardens to Soak Up Storm-Water Runoff

New York Times  - ‎Nov 7, 2014‎
Overflows are discharged into local waterways to avoid flooding the plants, which can harm water quality.) … The push for so-called green infrastructure projects across the country dates to at least 1987, when Congress revised the federal Clean Water

 

Play of the Game

I am an alumnus of Auburn University and fan of Auburn football. To many, Auburn’s team performance has been characterized in the last two seasons by single, spectacular, and game-winning (or losing) plays. Those are the plays that hit the highlight reel and let us easily judge and sum up our opinions of the quality of a team.AU

Last season, with unbelievable ending plays against Georgia and Alabama, it bothered me that the wins were often written off as sheer dumb luck. I knew that in order for those plays to have happened, the team had to be a position for them to happen.

The plays of the game against Texas A&M two games ago went the other way for Auburn. Two fumbles in last minute critical situations prevented Auburn from pulling off the win. Bad dumb luck? Maybe. But I would prefer to say that, once again, Auburn earned that circumstance. Fumbles, penalties, and dropped passes chipped away at any cushion Auburn might have built through good play.

Success and failure in stormwater, like in football, rarely truly hinge on a single play or event. We may point to a big storm, or even a perfect storm combination of several events as the reason for our failure. But the truth is often buried somewhere in the story of our dropped balls and other miscues along the way. Every play and every day counts. from planning to design and into construction; from managing sediment to erosion to water to work to communication; every step matters. Like football, we will never know the true effect of each play or action on the overall outcome of the project. But we can grasp the principle and know the benefits of cushion, and buffer, and earned grace.  The only way to build those is striving for excellence in everything we do (not perfection, excellence – there is a difference).

Our wins will not always be praised or even noticed. Nor will our losses always trigger boos from our opponents or fans. But they might.  And those possibilities are worth our consideration and our best effort on every play.

 

 

 

Response-Ability

Responsibility: our ability to respond.

The level of concern in the general public over the recently proposed rule attempting to clarify the definition of Waters of the United States really didn’t surprise me much. If the subject was even on their radar, it was because of clips and snippets of information provided to them from their favorite media source. The Clean Water Act and its historical and recent interpretation, implementation, and reason for existence is a long and complicated story. It’s is certainly not five O’clock news material.

And it also wasn’t a shock to see non-traditional, but more widely accepted “news” media take the opportunity to use the proposed rule to promote whatever agenda and support whichever party they may be leaning toward.

And what politician worth his salt would ever give up an opportunity to criticize a “government” action? Even if the action is demanded by politicians to clarify rules created by politicians that politicians (and even the Supreme Court) can’t sort out cleanly enough to implement.

Similar to politicians, interest groups and industry associations that must show action to warrant their existence (and membership numbers), would be crazy to not take a stand against Big Business or The Man to protect its subscribers’ way of life.

But I have been surprised by the water quality profession’s public response, or lack of one. There was obviously an opportunity and obligation to provide comment to the agencies. But larger than that, I think we missed a great opportunity to start or join the public conversation. The misunderstanding and misinformation appeared to be based on shock that tributaries are chemically, physically, and biologically connected to the bigger waters. Or an inability to imagine that the federal government was planning to regulate waters so small that a ship couldn’t float in them, in spite of the fact that this has been the case for decades.

It’s not often that water quality issues land front and center, right in the middle of your neighbor’s (and my Dad’s) living room. From farming magazines, to local newspapers, to Fox, CNN, and CNBC – the conversation was happening, sometimes is a very misinformed and twisted way.

But we sat to the side, had some discussions among ourselves, and worked on our comments to the agencies.

Why is that? Was the topic too complex to explain rationally to the uninformed? Was it not worth the hassle? Did it place us on the opposite side of our declared public politics? Or is it simply easier to whine with the whiners?

I have said before that the Clean Water Act set forth a very real expectation that we get better. If water quality professionals are unable or unwilling to sort the truth from the fiction, and publically articulate their knowledge and views (either way) on such important proposal to clarify such an important law, then who should?

The deadline for the comment period has passed. But there will be another opportunity to educate and inform the general public on this proposal and matters of water quality. The implementation of the rule will make larger waves in the news media than its withdrawal by the agencies. I encourage us to be ready for either. The 42 year-old goals of the Clean Water Act aren’t getting any younger, and the rate of improvement in the quality of our Nation’s waters still lags far behind our 42 year-old intentions.

Like change or not, please take time to fully investigate the reasons behind proposed change related to water quality and start sharing your knowledge and expertise outside of our own peer network. Clean water is way to important to only be publically discussed on talk radio.