Exciting New Nutrient Discharge Permitting Frameworks Protect Water Quality and Provide Compliance Flexibilities

摘要

A number of new approaches to nutrient discharge pennitting provide compliance flexibilities for wastewater utilities, while at the same time protecting receiving water quality. Some of these new approaches break the traditional mold of NPDES permitting that is largely based on control of toxics. Nutrient management to protect water quality is entirely different from toxics control and it seems logical that distinct frameworks would be appropriate for nutrients. However, the federal regulations have been somewhat of an impediment to the development of more suitable frameworks for nutrients because of the specificity of permit structural requirements. Now a new variety of creative approaches to nutrient permitting are available for reference for both regulatory agencies and wastewater utilities. These permitting frameworks illustrate the range of flexibilities available within the confines of the Clean Water Act and existing regulations. Advantages of these approaches include longer averaging periods, use of alternatives statistics for effluent limits, application of watershed management techniques, provisions for load trading and offsets, and the development incentives for nutrient reductions. Broader perspectives on nutrient management that embrace a watershed approach and incorporate adaptive management features may be more effective in accomplishing water quality objectives and engaging all stakeholders. Incentives for early nutrient reduction may provide a catalyst for implementation of process optimization, sidestream treatment, and application of new technologies that might otherwise not be pursued until later. These new nutrient discharge permit examples may provide inspiration for other wastewater utilities and regulatory agencies to develop innovative permitting frameworks that provide these benefits.