WRA Urges EPA to Use Adaptive Management Approach for Revised Dissolved Oxygen Levels

water

WRA Calls for Science Based Changes to Water Quality Criteria

U. S. Environmental Protection Agency Proposed Criteria Short on Data, Analysis

For Immediate Release

February 21, 2024

PA, NJ, DE, NY – The Water Resources Association of the Delaware River Basin (WRA) submitted comments yesterday on a United States Environmental Protection Agency (EPA) proposal to change water quality standards for sections of the Delaware River. WRA’s comments pointed out that the analysis on which EPA’s proposed criteria is based is technically flawed and may not be attainable even at a cost of more than $153 million per year. Instead, WRA urged EPA to adopt an adaptive management approach to build on the progress already made and projects that are in the works as the foundations for future standard setting.

WRA is a nonprofit, non-partisan and public information organization that promotes the science-based management of water resources within the Delaware River Basin to protect water dependent uses and enhance the long-term sustainability and resiliency of the river system. WRA’s members are water users of the Basin, providing drinking water, wastewater treatment, energy, and other critical services and products. 

EPA’s proposal is aimed at increasing dissolved oxygen levels for the Atlantic Sturgeon, an endangered fish that once thrived in the Delaware River and has been making a comeback since the implementation of the Clean Water Act in 1972. The new criteria proposed by EPA is higher than the Highest Attainable Dissolved Oxygen level scenario in a draft document prepared by the Delaware River Basin Commission after five years of study. EPA did not convincingly demonstrate that its proposed new dissolved oxygen criteria was either attainable or necessary to ensure recovery of Atlantic Sturgeon. The proposed criteria do not address many other factors critical to successful restoration of Atlantic Sturgeon.

WRA recommended that EPA adopt an adaptive management strategy that would 1) implement robust survey methodology and monitoring to measure long-term progress and 2) collaboratively advance improvements that will support the propagation of the Atlantic Sturgeon.  Adaptive management strategies have been successfully used in the Basin to measure progress over time and allow regulatory decisions to be tailored to demonstrated results. WRA asserted that such an approach would be suitable for these purposes. 

“As climate change compounds the challenges facing the sustainability of the Delaware River, it becomes even more crucial that we get the science right and bake in processes to adapt as we learn more,” said Skelly Holmbeck, Executive Director of WRA. “EPA’s proposal, based on poor data correlations and flawed data sets, could hinder water quality improvement in the long run and cause limited financial resources to be squandered.”

According to Preston Luitweiler, Chair of WRA’s Science and Policy Committee, “EPA could best advance the next level of water quality improvements in the Delaware Estuary by supporting regional programs through the Delaware River Basin Commission (DRBC) and the basin states, and by assisting regulated entities in securing federal funding for the improvements needed to meet new water quality standards.”

Contacts

Skelly Holmbeck, Water Resources Association of the Delaware River Basin (WRA), 561.707.3186, ed@wradrb.org

Preston Luitweiler, P.E., WRA Science and Policy Committee, jpluit3@gmail.com, 215.341.5052

About the Water Resources Association of the Delaware River Basin

WRADRB was established in 1959 by representatives from industry, public and private utilities and other organizations that had wide-ranging interests in water resources and sought to ensure public participation in the management of the Delaware River and its tributaries.

In 1961, the WRADRB successfully participated in the development of a federal-interstate compact and the creation of the Delaware River Basin Commission. Since then, WRADRB has remained active in monitoring activities of the DRBC and other agencies of the four Basin states.

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