Narrative nutrient pollution control criteria are problematic for protecting the health of local water quality, yet Governor Gianforte and the Montana Department of Environmental Quality are pushing forward with the implementation of narrative water quality standards in pollution permitting decisions. Here’s a quick top 3 reasons why narrative standards fail to protect our waterways.
- Narrative standards are subjective. Different permit writers will view a narrative standard such as “waters are to be free from harmful substances” differently, resulting in unequal application of the law, much less harm. We should be using precise scientific metrics to protect waterway health, not guessing. Likewise, we shouldn’t have to wait for pollution events to occur before we know there’s a problem, yet that is exactly how narrative standards function. By removing the numeric goal posts for nutrient pollution and ignoring scientific standards that tell us when a waterbody has reached a tipping point, DEQ will be reactive and wait until there is a visible issue before ratcheting down on nutrient pollution discharges. We shouldn’t rely on reactive processes when it comes to the health of our water.
- Narrative standards don’t hold point source polluters accountable. Point source polluters (wastewater treatment plants, refineries, mines, sewage, and other pipes directly discharging into rivers) need to be held accountable for the pollution they contribute to local waterways. Narrative standards take away the responsibility of major polluters, like cities and towns, oil and gas refineries, and mining corporations from making progress towards a clear goal. Inherently, most sectors need to invest in necessary upgrades in pollution control technology to protect local water quality; removing numeric goal posts means that duty just became a whole heck of a lot more uncertain. Montana DEQ should be proposing a system of regulations that use best available science – e.g., numeric criteria – to hold point source polluters accountable and using its authority of prospective new development and sprawl development to better protect local water quality.
- Narrative standards ignore the big picture. The State of Montana is taking a giant step backwards by reverting to narrative standards over numeric standards, putting us in a difficult position given the diverse threats to Montana’s waterways. In the face of climate change, warming river temperatures, variable snowpack, river flows and persistent drought, we should be taking a hard look at how we can meaningfully protect water quality across Montana. Instead of using strong, scientific criteria that proactively let us hold major sectors accountable for their pollution discharges, we are taking steps backwards on this “easy” initial step and still have no plan to address equally troublesome non-point source pollution, let alone build resiliency in our river systems to confront the realities of climate change.