Criticisms of Chesapeake Bay Models Are Off Base
By Richard Batiuk • Nov 11th, 2009 • Category: Environment, FeatureIn his October 22nd essay entitled Logic and Passion and the Chesapeake Bay, Dr. Schnare does a disservice to readers by ignoring the world-renowned science and extensive monitoring behind models used in Chesapeake Bay restoration decision making.
We encourage Dr. Schnare to put down his Jane Austen novel and pick up the latest in a long series of independent scientific peer review reports on the full suite of Chesapeake Bay models. And on this account we agree with the author—“Sounds dreadfully dusty and dry”—but very important when one wants to accurately describe the work of others.
Models are a tool for generating information and insights into managers’ what if questions for understanding the vast complexities of many sources of pollutants across the six-state Bay watershed, and for quantifying what actions are needed to ultimately achieve the states’ Chesapeake Bay water quality standards.
Many of the models being used in making Bay water quality restoration decisions—the air deposition model, population land change model, Bay watershed model, Bay tidal water quality and sediment transport model, and the Bay oyster and menhaden filter feeder models—are in their 3rd, 4th or 5th generation of development and scientific improvement since the early 1980s. Each has been independently reviewed by a panel of scientists with nationally recognized expertise. Each is approved by the state and federal Chesapeake Bay Program partners prior to management application. But these models are still just tools in the much larger and complex decision making arena of Chesapeake Bay restoration.
Though these models are based on hundreds of published works of scientific research, calibrated and verified based on decades of monitoring at hundreds of locations across the watershed and the Bay’s tidal waters, generating literally millions of individual data points, they are only as good as the science and data that goes into their development and application.
Thus, we do agree on one fact – we (that being all the watershed states, USDA, EPA, our conservation districts and farmers) would benefit from a more complete accounting of the conservation practices put on the ground by our producers. It is a component of information that we all share a responsibility for filling. However, like water quality monitoring and measuring pollutant loads from wastewater treatment plants, we must have a system in place to not only report but verify the full implementation of such conservation practices. Just claiming widespread implementation does not lead to better decisions, from the field scale on up, without verification.
The model of focus within Dr. Schnare’s essay is the Bay watershed model – the complex accounting tool that considers past and present land uses, pollution sources, human and animal populations, reported implementation of thousands of conservation practices and pollution control technologies, along with long term rainfall and other weather conditions and river flows. It is calibrated and verified to match up with actual measured stream and river water quality and flow conditions at hundreds of stations throughout the watershed across the past two decades. Thus, the Bay watershed model provides a solid representation of the ambient water quality conditions in the Bay watershed’s streams and rivers, which, in turn, directly reflects what’s happening on the land, what’s discharged from point sources of pollution and what falls on the land and water surface from air deposition.
The more accurately we – again, referring to all of us – measure, report and verify what’s happening on the land, what’s being discharged and what’s falling on the land/water, the better we are all positioned to understand relative contributions to pollution sources and how to proceed from here in restoring Bay water quality. For example, the six states, the District of Columbia and EPA are tracking pollutant discharges from 483 significant municipal and industrial wastewater facilities across the watershed. We are working together on the final stage of compiling similar data for almost 3,000 smaller municipal and industrial facilities. Given the latest version of the Bay watershed model is segmented to provide information at the county scale and for the smaller underlying watersheds below the county scale, accurate load reporting and location of the discharge facilities is critical to ensuring that loads showing up in the streams and rivers water quality data are traced back to these land-based sources.
No where else in the country, for such a large interstate watershed and waterbody, is there tracking, reporting and crediting at the scale and detail that is carried out every year in the Chesapeake Bay watershed. We all have been positioned to make better decisions given the application of these tools, the world-class science developed by our universities and colleges, and by the unprecedented monitoring networks across the Bay and its watershed generating data for the past decades.
But we can and must do better – better reporting, more verification of the full array of conservation practices and pollution technology controls that will help all us - from conservation districts to state capitals - make better decisions on restoring Bay water quality.
Finally, back to models. Someday soon the weatherman is going to predict rain. Now we may say that this prediction is just as good as their model’s representation of weather. We may say weather models don’t have all the inputs perfectly represented. We may say that, and we’d be right. But the prudent among us will take our umbrellas.
Richard Batiuk is the Associate Director for Science, U.S. Environmental Protection Agency, Chesapeake Bay Program Office
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My editorial reported on the Senate testimony of Molly Pugh, Executive Director of the Virginia Grain Producers Association, who complained of “the obvious lack of complete data about current implementation of conservation practices significantly skews water quality reports and publishes misleading pollution load reduction assignments for any one sector.” Ms. Pugh has not been alone in her concern.
The U.S. General Accounting Office found fault with EPA’s modeling efforts as did University of Maryland Professor Tom Simpson, the expert EPA selected to review its programs. Howard R. Ernst, a political science professor at the U.S. Naval Academy and one of the EPA bay program’s fiercest critics, said he saw these mistakes as part of the same problem pointed out by the GAO.
“The bay program has evolved into a public-relations machine,” Ernst said. “They’ve been spinning the data for so long that they’ve forgotten that they’re spinning.”
Jeffrey L. Lape, EPA’s bay program’s director, rejected that idea. However, Lape also said, the bay program’s success should be judged using the bay itself, not a computer simulation.
The focus of Ms. Pugh’s testimony was that a computer simulation which EPA itself has admitted has not been accurate enough to predict the efficacy of past pollution control efforts should not be used to determine who and how much to tax farmers and suburbanites.
EPA argues that “we must have a system in place to not only report but verify the full implementation of such conservation practices.” Because EPA has spent over $3 billion on the bay program since 1987, one would have thought they would have such a system in place by now. That is Ms. Pugh’s complaint. In response, on behalf of the Thomas Jefferson Institute for Public Policy’s Center for Environmental Stewardship, I extend the hand of scientific friendship to EPA. We will be happy to host a meeting with EPA and those from Virginia Tech, Virginia’s Soil and Water Conservation Districts, Virginia’s Department of Conservation and Recreation and Department of Agriculture and the Chesapeake Bay Foundation, all of whom have done exemplary work to foster environmental stewardship on Virginia’s farms and who have on the ground experience with agricultural conservation practices. These groups can quickly craft a system that will fill the gap Ms. Pugh identified and EPA has now confirmed.
Dave Schnare
Center for Environmental Stewardship
Thomas Jefferson Institute
There are a lot of words about these models but what I did not see is that they have been independently VALIDATED.
What that means is that the models should accurately predict the conditions actually found by actual water quality testing.
That’s the problem. They are citing the model results as if they are the facts when they’re not.
Where is the rank list of Virginia Rivers that show the highest levels of nitrogen and phosphorous?
For a given river – what sections have the highest levels and which have the lowest levels and how do they compare with the data in the major tributaries?
I do not see this data. How can we be determining policy which in turn determines what work will be done – and what work not done – and the costs based on models that do not accurately predict the actual conditions found in the water.
When I see the actually water quality conditions of the rivers in Va… and mean and std deviation of the model’s performance – I’ll have more confidence.
But we cannot be dictating policy with what appears to be a Ouija Board.
Can someone tell me when we will know that the Bay is clean enough? Using the oyster and menhaden population as the indicator is precarious, because disease may be too influential. Is dissolved oxygen a sufficient indicator? Of the various pollutants, what is the maximum allowable concentration? My environmental compatriot says that the Bay must be restored to its pristine condition, which he realizes is impossible (if only because we do not know the pristine condition). Ever shrinking allowable pollutant concentrations or increasing required oxygen concentrations also harbor an unending and costly pursuit of the impossible. So what are the target concentrations and what are the allowable temporary and seasonal deviations?
Frederick A. Costello, Ph.D.
Chair, Land Use Committee
Fairfax County Federation of Citizens Associations
12864 Tewksbury Drive
Oak Hill, VA 20171
703-620-4942
Here’s what the “model” is ignoring:
” ‘Toxic stew’ of chemicals blamed for intersex fish in Potomac
Conservancy suspects hormone-, drug-tainted runoff and sewage”
http://www.washingtonpost.com/wp-dyn/content/article/2009/11/11/AR2009111118805.html
and this is the problem. Are we actively testing and measuring these substances – hormones, prescription drugs, CAFO effluents, antibiotics and the like and do we have a database that maps out where these substances are and are not?
Is there a model for these substances?
Where is this information if this stuff is tested and reported?
How can anyone in the Chesapeake Bay cleanup community expect the public to understand and to effectively lobby at the local level for their communities and leaders to recognize the issues and to work on the specifics that need attention in their communities.
This whole situation is basically an exercise in inside baseball for the environmental professionals who , as far as I can tell, are relying on computer models that do not address the actual conditions in the field especially with regard to these new classes of toxics.
In the end – it may well be that these new toxics are as harmful and perhaps more so to aquatic life in the rivers and the Bay?
Not only those who might be affected by unfounded regulations should be outraged – but the general public should be also because it is their expectation that the folks involved in the cleanup – are actually effective at their mission.
How can this many people be involved at so many different levels and still not make even simple progress on being able to tell us what the contaminants actually are that are found in the rivers and where?
An October 2009 report from Environment America reveals from analysis of EPA’s own 2007 TRI (Toxics Release Inventory) that more than 250 million pounds of toxic waste are discharged into 1900 waterways in all 50 states; these releases are largely legal and permitted. The group’s conclusion is that a system that allows such massive pollution is poorly designed and enforced and does not meet the Clean Water Act objectives.
EPA is ignoring the role of toxics in the Chesapeake Bay Program, as well. We cannot expect any improvement in Bay conditions while trying to limit the approach to ONLY the same actions that have proven inadequate over the last 3 decades. While nutrients remain at levels that are too elevated, we cannot solve the problem by limiting the solutions to only some of the pollutants affecting water quality and bay populations.
If agriculture were the primary cause of Bay degradation, the Bay would improve as the area and activity of agriculture has declined. It has not because agriculture is not the primary cause of Bay degradation. Agriculture is, though, the “easiest” hit in applying new regulation. Shame on EPA for taking the easy way out while presenting a dishonest picture to the taxpayers.
I have been involved in various aspects of the Bay Program since its inception, including administration of a local program at the mouth of the Bay – you were all upstream from Virginia Beach. We raised the issue of toxics when TMDLs were being developed, to no avail. When the program set new goals after a decade, we had to point out that they had forgotten to include goals for agriculture – which were added hurriedly at the end of the process.
Until there is a transparent and thorough analysis of the problem, it cannot be solved.
Mary Heinricht
Ag Prospects
Richard Batuik is off base again.
See the link below for a thoughtful take on how the Bay Program has abused computer models for more than 15 years.
http://www.aspanet.org/scriptcontent/custom/staticcontent/t2pdownloads/ErnstCommentary.pdf
Howard Ernst
Author of Chesapeake Bay Blues and Fight for the Bay