Better monitoring for state’s waters
THE MASSACHUSETTS Water Resources Authority wants permission from federal and state environmental regulators to stop monitoring environmental conditions in the Massachusetts Bay. The MWRA wants to measure only the quality of the water coming out of its outflow pipe, not conditions potentially affected by the effluent. Granting this permission would be a mistake. It is essential to try to measure the conditions to be improved (or whose deterioration is to be prevented) and use those measurements to guide strategic and daily decisions.
The regulatory system tends to get calcified and more costly when environmental conditions are inadequately measured. Without frequent, timely data revealing changes in environmental conditions, regulatory systems tend to get obsessed with processes (writing regulations and policies, issuing permits, inspecting, and enforcing) rather than what those processes are designed to accomplish. This creates a dynamic that frustrates not only regulated parties, the public, and their elected representatives but even the regulators themselves. It focuses everyone on tasks rather than on understanding problems and their relative import, identifying effective solutions and, once found, promoting adoption of those solutions and continually searching for more effective and cost-effective approaches.
Consider the cleanup of the Charles River. In 1995, the Environmental Protection Agency shifted its work from issuing permits and assuring compliance with them to improving water quality. It was able to do this in part because the Charles River Watershed Association had begun collecting monthly water quality data at 37 points along the river and in part because then-EPA regional administrator John DeVillars explicitly set a goal that year that the Charles River would be swimmable in 10 years, a commitment subsequently embraced by his successors. Shifting its focus to meeting the goal of a swimmable Charles River compelled the EPA to search for information to find the causes of the river’s water quality problems. The Watershed Association’s monthly monitoring data about the river’s water quality proved a gold mine. It led the EPA to serious problems the agency would never have found had it looked only at the monitoring data it historically collected.
With access to monthly river water-quality data, the EPA was able to detect when a downstream monitoring site had an unexplained worse water-quality reading than an upstream one. When this occurred, EPA narrowed its search for problems to the area between the two monitoring locations. This helped EPA discover unlawful hookups to storm sewer pipes dumping untreated waste water directly into the river. The geographically dispersed monthly data readings also revealed grease balls at some pipe junctures similar to those that can plague homeowners, preventing untreated wastewater from entering pipes to the treatment plant and rerouting it instead into stormwater pipes that discharged directly into the river.
Data-driven discussions and decision-making enabled the EPA and the state to accelerate the cleanup of the Charles River. Water quality began to improve markedly within five years. It rose from being swimmable between 19 percent and 34 percent of the time between 1995 and 1997 to being swimmable between 39 percent and 65 percent every year since. Although the river is not yet swimmable 100 percent of the time, this data-rich approach made possible by monitoring data continues to inform ongoing efforts to achieve a swimmable river all the time.
The Charles River experience suggests why the MWRA should be required to continue monitoring water quality and marine conditions. So long as the MWRA discharges partially treated waste water into the Bay and until the long-term consequences of its past discharges are fully understood, it should bear the cost of assessing its impact. Perhaps the MWRA can cut its costs by financially supporting local nonprofits and universities to conduct some of its monitoring, but cutting costs by cutting its obligations to monitor conditions is a bad idea. Government and those it regulates make far better decisions when they can study up-to-date, relevant data about the conditions their actions affect. When they lack that, they tend to get stuck operating in a rigid and more costly world of rules without context.
Shelley H. Metzenbaum is director of the Edward J. Collins Jr. Center for Public Management, UMass-Boston, McCor- mack Graduate School of Policy Studies.