Marginalized monitoring adaptively managing urban stormwater.

Author:Scanlan, Melissa K.
Position::V. Adaptive Management Applied to Stormwater through VI. Conclusion, with appendix and footnotes, p. 32-71

    Congress and the EPA have established a legal framework for municipal management of illicit discharges to stormwater that is more adaptive than prescriptive. While the federal law clearly prohibits non-stormwater discharges from the MS4, it provides wide discretion to the MS4 to create and implement a plan to detect and eliminate these illicit discharges. The regulatory focus is on management actions informed by a system of monitoring discharge pipes instead of specific end of pipe pollution limits. This program seems influenced by the theory of adaptive management, which focuses on strategies that emphasize continuous monitoring of circumstances and adjusting decisions accordingly. (136) However, the program would benefit from carefully identifying and addressing the architecture needed to support a successful adaptive management program that produces better substantive results. (137)

    In this research we build on Professor Holly Doremus' work urging agencies engaged in adaptive management to more systematically address their information needs and understand how information is diffused to resource managers. (138) Professor Doremus outlined an information supply pipeline in her work, (139) and in our research we focused on how scientific information is "extracted" and used for better water management. As explained in section IV, scientists have developed innovations in the monitoring process to more accurately and efficiently identify the existence of human sewage. Thus, in the municipal stormwater context, we explored how highly relevant scientific developments by non-agency scientists are understood, diffused and applied to MS4 management to identify and eliminate illicit discharges of raw human sewage into our nation's waterways. Our research observations highlight impediments and incentives for scientific extraction that may be broadly applicable to other systems.

    1. Research Methodology

      We selected the Milwaukee metropolitan area because it is a study area with an existing body of scientific data on human specific bacteria in stormwater outfalls and ongoing efforts to gather data to characterize the extent of illicit connections in the urban area. Unlike much academic research, Dr. McLellan's findings of human sewage in stormwater were widely communicated to the public through the paper of record in Wisconsin. (140) Moreover, the study area is large enough to contain a variety of MS4s operating within it, producing a broader pool of potential interviewees.

      One needs to understand the MS4 managers' and state and federal regulators' perspectives, the influences on their decisions, and the systems in which they work to assess how and to what extent urban stormwater managers are incorporating scientific developments to better manage urban waterways. Through qualitative research interviews with the water managers, one can discern how they incorporate scientific advancements into their work, and the barriers and incentives to extracting relevant scientific information that could lead to positive substantive outcomes for water resources. (141) With this in mind, we undertook a series of qualitative research interviews with MS4 water managers, and stormwater regulators from the Wisconsin Department of Natural Resources (DNR) and United States Environmental Protection Agency (EPA). (142) In order to maintain the confidentiality of the interviewees, we omit their names and cities they serve and uniformly use the male pronoun when describing their responses.

    2. Research Findings

      All MS4 managers and state and federal regulators interviewed agree that bacteria in Milwaukee's watersheds is a problem, and that MS4s are a significant conveyor of bacteria. (143) However, some expressed uncertainty about how "bad Milwaukee's watersheds are compared to other urban watersheds" (144) or the extent to which MS4s are contributing to the impairments. (145) Milwaukee's watersheds are, in fact, impaired by bacteria. (146) However, bacteria are diverse and come from a wide variety of sources, with different levels of public health implications. Human source bacteria originating in human sewage has a greater potential to make people sick, for instance, than bacteria from pets or wildlife. (147) Additionally, the follow up for bacteria from wildlife should be different than for human sewage in stormwater. (148) However, our research shows that neither the Clean Water Act regulatory framework nor the people charged with managing urban waters are actively adapting to, or extracting, scientific innovations to detect and eliminate illicit discharges of raw human sewage.

      We first identified the regulatory impediments to adaptive management contained in the Clean Water Act and its implementing regulations and then explored the additional non-regulatory obstacles to adaptive management. We focused on how adaptive management theory could be more rigorously applied to aid the transfer or extraction of knowledge from 3rd party scientists to resource managers.

      A critical aspect of adaptive management is that managers understand and incorporate evolving scientific knowledge into their management decisions. (149) Adaptive management may be most useful in environmental management situations where numerous factors and response relationships prevail; the knowledge about those factors and the relationships are not fully identified; and the systems are often dynamic, rather than static. (150) Managing urban stormwater to identify and eliminate illicit discharges of human sewage is theoretically well suited for an adaptive management approach because the discharges are often intermittent and the sewersheds can be large and complex. Further, the program requires regular monitoring of outfalls during dry weather to detect possible illicit sources, and scientists have developed new monitoring techniques that can quickly and accurately identify sources of human sewage that pose significant human health risks. However, adaptive management will not deliver superior management results if water managers fail to actively seek new information and modify their management approaches accordingly.

      We first assessed whether MS4 managers clearly understood the goals of their programs, drawing from Lawrence Susskind's work on adaptive management in the Glen Canyon observing problems that arose from the absence of guidance on management goals. (151) Unlike the Glen Canyon case study, most of the MS4 managers reported they had clear goals to eliminate all illicit discharges from their urban storm sewers. (152) This clarity mirrors the prescription from Congress to prohibit all non-stormwater discharges into MS4s. (153)

      Since the goals of the program were clearly understood as detecting and eliminating all illicit discharges, we next analyzed how managers incorporated science into accomplishing those goals in order to examine the information flow problems observed by Holly Doremus. (154) We generally assessed how the interviewees understood and incorporated scientific developments. We also focused more specifically on new monitoring breakthroughs pioneered by Dr. McLellan's research on human sewage in stormwater discharges in their management areas. At the outset, we established that none of the government entities interviewed--from the MS4s to the state and federal regulators--conducted any controlled experiments on illicit discharges. (155) While controlled experiments are not the only form of science, this does underscore the importance of whether and how stormwater managers stay current with scientific advancements by non-agency scientists who are conducting controlled experiments and researching new monitoring methods.

      Those MS4 managers and state and federal regulators who were aware of Dr. McLellan's research were enthusiastic about its utility for MS4 management related to identifying and eliminating human sewage from stormwater. Several characteristic responses follow:

      She has unlocked some of the secrets so you can fine tune your efforts to get at the source of the problem. That is so important in times of tight budgets because now more than ever we need to be more efficient with our methods so we can quickly identify the source of a problem that needs to be fixed. (156) The existence of bacteria with the standard coliform test can mean many sources. When you can pinpoint it is human, that helps focus resources in areas that are more problematic. (157) This research answers the source question. If it is human sewage, then it is related to infrastructure that we control in part. If it is raccoon poop, we can't control that. If it is dog waste, we can educate, but we can't control individuals picking up after their dogs. (158) Distinguishing the source of the bacteria is "really important for storm sewer outfalls because we don't want to chase a natural background problem." (159) Human specific bacteria testing could go a long way to define where problems are within an area. "If we could take this test up the system and narrow down which line of sewer it is coming from, that would be helpful." (160)

      One MS4 manager suggested that this type of research has a widespread utility because identifying the source of bacteria "is a dilemma all over the country." (161) A regional EPA stormwater regulator who works with multiple states similarly recognized the breadth of the problem with sewage contamination. (162) He further stated, "We understand that all bacteria are not equal. They have different health implications and we need to tailor our programs to better address the sources of bacteria." (163) Depending on the type of bacteria you find, it helps fingerprint the source. "Using human specific testing would help us better protect public health, spend time more effectively, and not chase after problems that don't exist." (164)

      One interviewee had experience using human Bacteroides results from Dr. McLellan's...

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