Water: Monitoring & Assessment
Elements of a State Water Monitoring and Assessment Program
Clean Water Act §106(e)(1) requires EPA, prior to awarding a Section 106 grant to a State, to determine that the State is monitoring the quality of navigable waters, compiling and analyzing data on the water quality, and including those data in the State's section 305(b) report.(7) Historically, EPA has relied on submission of the 305(b) report to determine that States have satisfied the Section 106(e) eligibility requirement for the award of Section 106 grant funds. As explained in the FY2001 Clean Water Act Section 106 Grant Guidance, Regions have begun conducting reviews of State monitoring programs and are working with States to strengthen these programs over time .
States have taken very different approaches, within their resource limitations, to implement their monitoring programs. They have applied a range of monitoring and assessment approaches (e.g., water chemistry, sediment chemistry, biological monitoring) to varying degrees, both spatially and temporally, and at varying levels of sampling effort. It is not uncommon for the reported quality of a waterbody (i.e., attainment or nonattainment) to differ on either side of a State boundary. Although some differences can be attributed to differences in water quality standards, variations in data collection, assessment methods, and relative representativeness of the available data contribute more to differences in assessment findings. These differences adversely affect the credibility of environmental management programs.
EPA has issued national guidance to promote and structure consistency in State monitoring programs and to ensure that the Section 305(b) process provides nationally comparable data with known accuracy [ 2, 3]. However, experts charge that EPA remains unable to make credible statements about differences in environmental quality over time and across the Nation [4, 5]. Also, in 1998, the Federal Advisory Committee on the Total Maximum Daily Load (TMDL) Program recommended that EPA assure needed improvements in State efforts to monitor water, characterize the general health of aquatic systems, and determine (non)attainment of any component of water quality standards, including narrative criteria and designated uses . A 2001 National Research Council report, Assessing the TMDL Approach to Water Quality Management, recommends, among other things, the development of a uniform, consistent approach to ambient monitoring and data collection; increased resources for water monitoring; the coordination of monitoring with program needs; endorsement of statistical approaches and explicit acknowledgment of uncertainty; and the combining of monitoring and modeling .
And most recently, a 2002 National Academy of Public Administration report, Understanding What States Need to Protect Water Quality, notes that improved information on water quality conditions, pollution sources, and program results will help states make more effective use of limited resources .
The purpose of this document is to recommend the elements of a State water monitoring program, to provide a framework for the State to articulate its programmatic and resource needs, and to serve as a tool to help EPA and the State determine whether a monitoring program meets the prerequisites of CWA Section 106(e)(1). EPA recognizes that full implementation of these elements will take time and resources and that currently many states do not fully meet these elements for all their waterbody types. For a State lacking many of the elements, this implementation process may extend over a period of up to 10 years. EPA expects the State to define annual milestones for incremental progress toward implementation of the ten elements and to include these in its work plans for Section 106 grants and Performance Partnership Grants (PPGs) that include Section 106 funds, consistent with the regulations governing the negotiation of work plans at 40 CFR 35.107.
1. U.S. Environmental Protection Agency (U.S. EPA). 2001. Memorandum on FY 2001 Clean Water Act Section 106 Grant Guidance signed February 16, 2001 by Michael B. Cook, Director, Office of Wastewater Management.
2. U.S. EPA. 1977. Basic Water Monitoring Program. U.S. Environmental Protection Agency Standing Work Group on Water Monitoring. EPA 440/9-76-0252.
3. U.S. EPA. 1997. Guidelines for Preparation of the Comprehensive State Water Quality Assessments (305(b) Reports) and Electronic Updates. U.S. Environmental Protection Agency, Office of Water. Washington, DC. EPA 841-R-97-002A and 002B.
4.National Academy of Sciences. 1977. A Report to the U.S. Environmental Protection Agency from the Study Group on Environmental Monitoring, Committee on National Statistics, National Research Council. National Academy of Sciences, Washington, DC.
5.General Accounting Office. March 2000. Water Quality-Key EPA and State Decisions Limited by Inconsistent and Incomplete Data. GAO/RCED-00-54.
6. National Advisory Council for Environmental Policy and Technology (NACEPT). 1998. Final Report of the Federal Advisory Committee on the Total Maximum Daily Load (TMDL) Program
7. National Research Council. 2001. Assessing the TMDL Approach to Water Quality Management, Committee to Assess the Scientific Basis of the Total Maximum Daily Load Approach to Water Pollution Reduction. National Academy Press, Washington, D.C.
8. National Academy of Public Administration. December 2002. Understanding What States Need to Protect Water Quality. Academy Project Number 2001-001. http://www.napawash.org.