Nowhere will implementation of the Environmental Protection Agency's total maximum daily load (TMDL) requirements be more complex than the Delta, Mississippi Department of Environmental Quality Director Charles Chisolm told farmers at the 2001 annual meeting of Delta FARM.
In fact, he says, the Delta presents its own set of challenging circumstances to those served with implementing the regulations included as part of the Clean Water Act.
The Environmental Protection Agency's total maximum daily load (TMDL) regulation mandates that each state determine if its water bodies meet strict water quality standards and, if not, provide for any quality based control necessary.
Chisolm calls the TMDL regulation “really nothing more than a very sophisticated water quality study.” Despite that, he says, “The issue of TMDLs is a very critical issue here in the Delta because it has the potential to profoundly affect the area's farmers.”
Current federal TMDL regulations mandate that states identify which water bodies are pollution “impaired,” whether by point source discharge, such as waste water treatment plants, or whether by non-point source pollution, such as water run-off from crop fields. In addition, each state must establish priority rankings for their list of “impaired” water bodies and then set total maximum daily load limits to determine the amount of pollutants each body of water can assimilate and still be able to meet water quality standards.
“Over the past 30 years most water quality studies have focused more on point source pollution than on non-point source pollution. Now that focus is beginning to shift,” Chisolm says. “We are well underway in carrying this regulation out statewide in Mississippi, but there is no other area that will be more complex when it comes to TMDLs than the Delta. There is also no other environmental quality related area where we have to have more collaboration than this one.”
“Often, people don't care much about what's going on during the planning phase of an environmental program, but then they get really interested when it's time for the implementation phase,” he says. “I'm telling you that if you wait until the implementation phase to get interested, you're waiting until it is too late. At that point, all you are going to do is be along for the ride, you are not going to influence policy on the issue.”
The total maximum daily load issue isn't the only environmental regulatory area that is need of voluntary collaboration between farmers, industry members, and government agencies.
“There are an enormous number of instances where the environment and the economy are intersected,” Chisolm says. “We have a regulatory responsibility to make sure water bodies are used in a way that does not degrade the environment. But, we need to make sure that collectively we are making the right decisions. Please think about this business of collaboration, talking and listening.”
Chisolm says there are several policy areas the Department of Environmental Quality is working on today that would benefit from voluntary collaboration. Among these, he says, are wetlands issues, the Gulf Coast hypoxia issue, the Sunflower River project, and aerial application safety.
In addition, he says, the Environmental Protection Agency is considering that permits be issued for any discharges from catfish ponds. “We don't think this is a wise use of our resources, but nevertheless EPA is looking at it. Some of us believe that despite our best efforts, EPA still doesn't understand this industry, and what it means to Mississippi.”
“We want to make the best decisions that we can possibly make on all of these issues. But, to do that, we need all of the right people at the table to decide what the best solutions are for the Delta,” Chisolm says. “One of our greatest challenges is to keep the environment safe while also growing the economy of the Delta and the state. In order to do that optimally, we've got to do it collaboratively.”