What is Next for the Greater Milwaukee Watersheds?

The Future of the Southeastern Wisconsin Watersheds Trust - A Business Perspective

Clean Rivers, Clean Lake VI August 31, 2009 David Lee, P.E. We Energies

SWWT Business Perspective

Overarching view:
Water quality improvements, over the past almost 4 decades since enactment of the CWA, have been primarily due to the financial resources directed toward point source controls. For about the past 2 decades wide recognition that non-point sources controls would be the most noncostcost-effective means of improving water quality.

SWWT Business Perspective

Overarching view:
Industrial wastewater treatment and pretreatment systems have been successfully operated since the 1970s. Storm water management/erosion control plans are implemented for nearly all construction projects and for most operating industrial facilities.

SWWT Business Perspective

Overarching view:
Air emission control systems also have reduced the atmospheric loading of pollutants to waterways. Land quality programs are generally mature, incorporating recycling, beneficial resuse (e.g., fly ash use in concrete), groundwater monitoring and advanced landfill design requirements.

SWWT Business Perspective

Overarching view:
We are often in situations of being at a point of diminishing returns for environmental control investments.

SWWT Business Perspective

Example Pollutant reduction of 99.9%
Discharge reduced to about 0.1 lb/year => Annualized cost of about $25,000/lb removed To remove remaining 0.1 lb/year => Annualized cost = $20,000,000/lb removed 1000 1000 1000 situation

SWWT Business Perspective

We sometimes find our selves in situations where expectations and reality are out of synch: Example Emission reductions from solar and wind power projects are less than expected. Study in ES&T reported that such projects were only achieving about 30-50% of expected NOx 30emissions. [Note that many renewable energy sources need
to backed-up w/fossil fueled sources.] backed-

SWWT Business Perspective

Why SWWT I dont know, but heres what I think SWWT can facilitate: Collectively, we need to figure out the most cost-effective coststrategy to get at the remaining low hanging fruit. Collectively, we need to openly communicate to align expectations with reality. Collectively, we need to work toward law and policy changes that encourage collaboration to most efffectively spend the next environmental control dollar.

SWWT Business Perspective

Elaborating on the last point, TMDL program use should be the exception. My view this program has evolved into something that is far beyond what Congress likely envisioned in 1972. It is complex, difficult to implement and probably too narrow (impaired water focus) a regulatory program to suit our purposes.

SWWT Business Perspective

Take the Friends of Pinto Creek v. EPA as an example. In concept, this sounds like something that should have worked an NPDES permit for a new discharge, into an impaired water subject to a TMDL, required the company to more than offset its new pollutant load by implementing a clean-up cleanat an upstream abandoned mine.

SWWT Business Perspective

Friends of Pinto Creek v. EPA : Environmental groups challenged EPAs determination, and, in 2007, the Ninth Circuit Court of Appeals ruled against EPA, specifically rejecting the offset approach because the permit did not include a compliance schedule to ensure achievement of water quality standards.

SWWT Business Perspective

We think in generalities, but we live in detail.

Alfred North Whitehead, British mathematician and philosopher, (1861 - 1947).