EPA’s BASINS MODEL –GOOD SCIENCE OR SERENDIPITOUS MODELING? Ray C. Whittemore 1, John A. Beebe 2 National Council for Air and Stream Improvement, Inc. ABSTRACT Better Assessment Science Integrating Point and Nonpoint Sources (BASINS) is a geographic information system based tool developed by EPA's Office of Water to help states more efficiently target and evaluate water-bodies that are not meeting water quality standards. BASINS (EPA, 1996a, 1998) brings together data on water quality and quantity, land uses, point source loadings, and other related spatial data with supporting nonpoint and water quality model at a quicker and more effective pace. EPA developed BASINS, a geographic-based watershed tool to better integrate point and nonpoint source water quality assessments for the Nation’s 2100+ watersheds. In its zeal to achieve this endpoint, EPA has initiated a simplistic approach that was expected to grow through scientific enhancements as TMDL developers become more familiar with modeling requirements. BASINS builds upon federal databases of water quality conditions and point source loadings for numerous parameters where quality assurance is suspect in some cases. Its design allows comprehensive assessments and modeling in typical Total Maximum Daily Load (TMDL) computations. While the TMDL utility is the primary reason BASINS was developed, other longer-range water quality assessments will become possible as the Agency expands the suite of assessment models and databases in future releases. The simplistic approach to modeling and user-friendly tools gives rise, however, to technical and philosophical concerns related to default data usage, seamless generation of model input files, and the failure of some utilities to work properly suggest to NCASI that serious problems may still exist and prompts the need for a more rigorous peer-review. Furthermore, sustainable training becomes paramount, as some older modelers will be unfamiliar with (Geographic Information System) GIS technology and associated computer skills. Overall, however, BASINS was judged to be an excellent beginning tool to meet the complex environmental modeling needs in the 21st Century. Key words – watersheds, modeling, GIS, TMDL, quality assurance INTRODUCTION EPA’s Watershed Initiative, started in the early 1990s, provides a regulatory approach to environmental protection programs different from the ‘command and perform’ scenarios of the Clean Water Act in 1972. The new approach places the entire watershed as the unit of regulatory focus rather than individual rivers or stream segments. While this approach has garnered worldwide attention and support, some still question its wisdom given that some states have effective nonpoint source control programs in place and water quality in most locations is 1 Principal Research Engineer, National Council of the Paper Industry for Air and Stream Improvement, Inc., Tufts University, Medford, MA 2 Research Scientist, National Council of the Paper Industry for Air and Stream Improvement, Inc., Tufts University, Medford, MA 1 gradually improving (per recent EPA 305b report) using wasteload allocation approaches of the 1970s and 1980s (EPA, 1998a). States are presently required by the Clean Water Act to determine the total maximum daily load (TMDL) of pollutants in areas where technology-based controls alone are not adequate to achieve compliance with water-quality standards. The federally mandated requirement is to develop wasteload allocations specifically for point sources of pollution and load allocations for the nonpoint (diffuse) sources. If a State fails to meet these requirements of the Act, EPA is mandated to assume responsibility and to develop TMDLs as necessary to carry out and meet its goals. In 1996, EPA was defending itself in litigation around the country brought by environmental groups challenging the slow pace of TMDL development. In response to growing pressures to develop Total Maximum Daily Loads (TMDLs) assessment tools, EPA created a new flexible modeling system (BASINS) to more effectively integrate assessment of point and nonpoint pollution sources. While the events that prompted the BASINS research and development justified the attention, some TMDL process and modeling related tasks are currently still controversial and will continue to confound watershed stakeholders for many years to come. Unquestionably, a set of easy to use and robust water quality assessment and modeling tools are needed for quantitative watershed assessment on the scale of the present TMDL needs. Will BASINS ever become this tool? The answer is probably ‘yes’, but EPA needs to more seriously address quality assurance and provide sustainable technical support and training for an increasing array of users. BASINS OVERVIEW AND HISTORY BASINS v.1.0 (EPA, 1996a) was the inaugural tool that brought together data on water quality and quantity, land uses, point sources, and a limited suite of water quality models to perform watershed-scale assessments. The current suite of models is expected to expand as users develop experience, gain familiarity, and master skills with GIS geographic information system-based approaches to watershed assessment and management. This is an important and highly significant trend in environmental management that emerged in the late 20th Century. Extremely useful utilities in the BASINS’ tools are the water quality assessment tools – TARGET, ASSESS, and DATA MINING. As with most GIS-based approaches, powerful display and summary graphic information is created for visual or written reports. This feature is critical in the watershed assessment arena and makes BASINS worthy of attention and the time investment to learn its functionality. If these utilities are to provide the foundation for reliable water-quality assessments, their quality must be assured through the established peer-review process. To date EPA has not promoted comprehensive peer-review as a priority and, thus has not forced a critical evaluation of the databases inherent to BASINS. Instead, the approach has been to rely upon the respective developing programs such as PCS (Permit Compliance System), STORET (STOrage and RETrieval database of water quality data), and NSI (National Sediment Inventory) to develop assurance measures. In mid-1998, EPA commissioned a minimal peer-review of BASINS, nearly two full years after its public release and distribution. The assignment to the three reviewers included: (a) a review 2 of the BASINS package consisting of the choice of data layers, the analytical and reporting functions, and the linkages between the components; and (b) an evaluation of whether BASINS provided a sound, credible tool to EPA Regions, states, and local governments for developing TMDLs for a large percentage of their 303(d) listed waterbodies. The objective did NOT include evaluation of commercial software application (ArcView 3.0a/3.1), the national spatial databases, the models themselves, or most importantly the array of default parameters meant to give the new user a ‘quick start’ in model development. Because only three reviewers were included, robust and unequivocal conclusions were precluded. The sample of three was, however, supportive of BASINS’ development in the TMDL program. While good science in modeling practice would dictate that the initial data choices be critically examined during model calibration, it will not always happen in some priority, time-sensitive situations. In spite of advances in model sophistication, including complex models such as HSPF, effective calibration is still an ‘art’ where multiple parameter datasets can achieve the same degree of simulation matching to monitoring data. In the peer-review report (EPA. 1999), EPA notes that both Qual2E and HSPF are established models with prior peer reviews and that other EPA or Federal agencies are responsible for data QA/QC. In effect, EPA has concluded that a majority of the BASINS users will have sufficient professional judgment and insight to use the system wisely and to fairly represent the results to the broad array of TMDL stakeholders. This laudable expectation hopefully will be realized in the coming years and will be subjected to continued scrutiny by all users, including state and federal agencies, and academia. There are those who would argue, however, that there are too many TMDLs to be developed for the universal application of good science and that quality compromises will occur. It is further interesting to note that despite the perceived widespread acceptance and use of BASINS, few reports have been published or are available on BASINS’ applications. Publication of varied technical experiences and problem solutions is an effective means of technology transfer and is at the core of scientific advancement. BASINS WATER QUALITY MODELS The current version of BASINS is built around the models - HSPF, QUAL2E, and TOXIROUTE. Except for TOXIROUTE, these models represent state-of-the-art efforts from the EPA Center for Exposure Analysis and Modeling (CEAM) in Athens, Georgia (EPA, 1993) for nonpoint, point sources, and toxic compounds, respectively. The nonpoint source model is version 11.0 HSPF (Hydrologic Simulation Program Fortran), and called “NPSM” within the BASINS interface. It is a critical component of BASINS because it simulates the meteorological and land-based processes important to the understanding the sources of nonpoint source loadings required in TMDLs. HSPF is a PC-based adaptation of the Stanford Watershed Model, the premier hydrologic land-based simulation model of the 1960s and 1970s (Crawford and Lindsey, 1976), and has a substantial following, in spite of the fact that it is hard to understand and effectively use. QUAL2E (Brown and Barnwell, 1985), on the other hand, has become the model of choice for point source modeling of organic and nutrient pollutants and used extensively for wasteload allocation in the past three decades. The remaining model, TOXIROUTE, is a simplistic toxic fate model with limited chemical fate simulation capability (GSC, 1993). In spite of the use of its predecessor PROUTE (an older EPA dilution model), it 3 lacks current stature within EPA and will be discontinued in future BASINS releases (Kinerson, 2000). HSPF is a lumped parameter, continuous simulation nonpoint source model that provides powerful simulation potential when used by knowledgeable personnel. Achieving this state of expertise, however, still remains a formidable task even to experienced modelers. Expertise in this area amongst state modeling staff is highly variable. Maryland, because of its proximity to EPA’s Chesapeake Bay Program Office in Annapolis where HSPF has been applied many times, is one of the few states with this expertise. Other states rely upon consultants or still use empirical washoff and loading functions, common in the decades of the 1960s, 1970s, and 1980s. Currently, EPA is not aggressively addressing these limitations in its training schedules, primarily because of funding limitations. Unfortunately, users of BASINS/NPSM are quick to assume that the problems they encounter are HSPF problems. This is not necessarily a correct assumption as, in our testing, most problems were frequently correlated with the BASINS interface itself or user specific setup issues. Those that follow the EPA BASINS ListServer on the BASINS web site, an interactive user communication medium, have noticed that many problems that are related to importing new (non-default) or local data and other problems related to installation. Early NCASI experience echoes these problems and strongly advocates more complete user guidance, including case studies and tutorials to alleviate many of these problems by advancing detailed guidance. EPA’s posting of a series of technical notes on the BASINS web site has addressed some of these issues, but more is needed. HSPF has undergone a series of updates and code changes since its adaptation from the early Stanford Watershed Model and predecessor HSP (EPA, 1996b). Numerous applications in the 1970s are significant because they were the driving force behind making HSPF the Agency’s premier nonpoint source model. Furthermore, these numerous experiences have led to HSPF becoming a robust watershed analysis tool. Both EPA and the USGS have adopted HSPF in their watershed analyses and will continue to improve features and promote its widespread use. In fact, the Army Corps on Engineers at the Waterways Experiment Station in Mississippi has recently endorsed HSPF and will devote its modeling resources to HSPF development (Donigian, 1998). Complex code in models such as HSPF effectively precludes a detailed examination of code integrity, such as that performed on QUAL-II by NCASI (NCASI, 1984). One should not assume that the code is infallible, as some combinations of model processes could be incorrectly coded, or otherwise problematic as was found in the NCASI analysis of QUAL-II and more recently in BASINS/NPSM trials. Stakeholders in contentious TMDLs will demand that the tools be of unquestionable veracity when faced with expensive treatment upgrades or restrictive land management BMPs. A major criticism of HSPF is that it is a non-distributed model and is, therefore, unable to handle the variety of site variables important for assessing multiple land use management effects at a meaningful field-scale. This includes variations in topography, soils, vegetation, and management activities (including roads). A second important problem is that the model is not physically based. This means that even though you can accurately calibrate the model (which can be done by manipulating the numerous coefficients), it can be difficult to understand and communicate changes in hydrologic or water quality function associated with the management action. The linkage between the change in site properties and the model coefficients is either 4 poorly defined or not well understood by many, in spite of its 30-year history. Given the regulatory uses of such models in the years ahead, the Agency needs to foster stronger links between model parameters and algorithms and management practices (BMPs) so that TMDL implementation has a more direct physical linkage to the analytical tools used in their development. This will facilitate better lay-public stakeholder understanding and acceptance. QUAL2E developed in the 1980s by EPA, Tufts University, and NCASI is an evolutionary product of a stream water quality model introduced by the Texas Water Development Board with later modifications by Water Resources Engineers. A Windows version was released in 1995 (EPA, 1995). The core model (and various nearly equivalent state versions) has been used extensively for waste load allocation studies in the U.S. and for river water-quality assessments worldwide since it’s development in the late 1970s through the late 1990s. EPA and others promoted this utility through hands-on stream modeling workshops in the mid- to late-1980s, which regrettably have stopped. The model is consequently well known in state agencies and used preferentially over others in waste load allocation and TMDL assessments. This type of consistent training is needed for BASINS. Although it will no longer be free, NCASI was encouraged by recent Agency announcements on the BASINS web page regarding training opportunities in academia through mid-2001. This level and quality of hands-on training is representative of what’s needed for the BASINS toolkit to achieve its promise. Additional further outreach to academia may prove productive by developing BASINS skills in waterquality personnel early in their career development and challenge faculty to develop research enquiries. Within BASINS the QUAL2E model is parameterized by nontransparent data inherent to EPA’s river reach file (RF1) and includes data necessary to simulate both hydraulics and water-quality. Rather than creating the input file by examining the characteristics of each reach separately, BASINS extracts the necessary information and seamlessly creates this file. While the user can still edit it on an individual reach basis, the initial effort of configuring the river system, assigning connectivity, and populating the model parameters provides the modeler with a unique opportunity to better understanding of the physical system and, therefore, a higher comfort level with the application. While this utility is of significant help to new HSPF users in dealing with cumbersome input format, the essence of the criticism is equally valid for both models. The seamless utility of the BASINS user interface, while easing the burden of data entry into an exacting file format, is viewed suspiciously by many experienced modelers and judged a poor idea by others. NCASI supports these viewpoints, as modeling should not be made easy at the expense of good science. Some industrial stakeholders’ fear that some TMDL modeling assessments will be formulated with minimal effort and conceivably could be only desktop activities. As noted earlier, TOXIROUTE will be discontinued in future releases of BASINS in FY 2000/2001. In its present form TOXIROUTE is too simplistic for all but trivial screening level applications, primarily because many toxic substances interact with sediment and biota in a complex way. No interactions between toxic pollutants and other water quality constituents are allowed in TOXIROUTE. 5 DATABASE QUALITY ASSURANCE At the cornerstone of quality assurance, BASINS’ users rely upon the completeness and overall accuracy of background GIS data used in the program as default information. Over the past several months, EPA’s Office of Water has compiled and made available metadata records for most of their geographic coverage. Many of these records, unfortunately, are incomplete or suggest data quality that does not comply with the content of the standard for digital geospatial data (USGS, 1998a). In a more detailed assessment (NCASI, 1997) evaluated data in one database (the Permit Compliance System - PCS) and found the following types of errors (see Table 1) for 50, randomly selected, pulp and paper mill facilities. While the implications of these errors will vary according to facility, some can lead to erroneous analyses and unfairly influence regulatory decision-making. It is presently unknown how widespread these errors are across all industrial categories, but the fact that they may still exist in this one industry’s database is cause for caution in general. It is known that some paper industry facilities reported problems to state/federal agencies with unknown results. In every case, the modelers developing the TMDL and the stakeholders affected by the analysis have a responsibility to acquire accurate information and to note problems where they occur. Since the BASINS software is available to anyone free-of-charge, rogue analyses are always possible and even probable in some adversarial situations. The general public is ill equipped to distinguish the good-science from inappropriate analysis when it comes to technical watershed assessment and modeling issues. Most water quality professionals would acknowledge that these resources are not infallible and error free. All of the spatial data products imported into the BASINS toolkit should be part of an ongoing quality assurance process. In doing so, all spatial data should retain original metadata records to maintain government compliance standards set forth by the Federal Geographic Data Committee and should evaluate usability of data by completeness of these records (USGS, 1998a). Table 1: Paper Industry PCS Error Summary (NCASI, 1997) CATEGORY # of MILLS No Errors 5 No Typos 9 Minor Typos (defined as those that are less than one order of magnitude from the expected value, not easily detected, or have no impact on the resulting use) < 5 records containing errors 16 > 5 records containing errors 10 Major Typos (defined as those greater than one order of magnitude from the expected value) < 5 records containing errors 15 > 5 records containing errors 2 Unit Errors (incorrect units) 9 Missing Data (data submitted but not 2 recorded) Truncated data (data that exceeds the 2 database field width – generally those with 6 qualifiers such as > or < Limit Errors (those that incorrectly state permitted limits stated in DMR reports) 3 WATER QUALITY DATA PROVIDED IN BASINS While any one watershed (also known as a cataloging unit) may contain over one hundred water quality observation stations, only 15 (or less) per watershed were selected for use in BASINS, because of space limitations in the CD ROM distribution format. The observation stations represented were “selected (by EPA) because they have more data than the average water quality station and thus provide a better starting point for comparisons with simulation model output (e.g., QUAL2E, NPSM).” It would appear that, based on the location of the stations in the vicinity of the test watershed examined in this evaluation, that little or no consideration was made to choose stations that were evenly distributed throughout the watershed. In the test watershed (Figure 1), the data from the 15 observation stations examined represented daily observations for many different water quality parameters and the frequency of these observations were highly variable per station and year. For example, while there were a total of 782 dissolved oxygen observations distributed among nine of the 15 stations, there were no BOD observations for the entire watershed. Additionally, at one station there were 60 observations in one year for one parameter and then only 12 the following year for the same parameter. These inconsistencies would make it difficult for any modeler to calibrate a subset of the water quality parameters for the watershed in question. Confounding things further, the arrangement of the water quality stations was such that it did not account for many of the main tributaries. Note the darker streams that are accounted for by STORET WQ stations (dotted circles) compared with the lighter streams in. It is also interesting to note that, out of the 15 stations located in this particular watershed, there is not a single one that is located at the pour point of the watershed. This would make it very challenging for modelers to calibrate a watershed of similar size and structure at the scale that was originally intended for BASINS applications. Figure 1 Utility of STORET Water Quality Stations in BASINS 7 In addition to the potential shortcomings of the PCS database, a number of other limitations have been revealed by NCASI Staff, EPA and other users of the BASINS modeling package. Table 3 highlights some of the key limitations of several datasets included as default information in BASINS. Additional information is available at http://www.epa.gov/OST/BASINS/metadata.htm. Table 3. Key Limitations of Default Datasets in BASINS. Dataset Landuse Watersheds Elevation Soils Rivers Streams Segments Hydrology Weather Limitation Limited spatially to 1:250,000 and temporally from 1977 to the mid-1980’s. Use with large scale data (i.e., 1:24k hydrography) is beyond resolution capabilities. Resolution of data (300 meters) is unsuitable for smaller subwatershed delineations. Positional accuracy between physical boundaries and digitized locations is unknown. Flow data not updated since 1982 and some RF1 reaches not reported (see list below). Stream locations are missing, disconnected or flow direction is incorrect. Channel geometry data is missing or misrepresentative of real physical conditions. Gauging stations with missing data or observations required general estimates1. Station locations cannot be averaged and data cannot be written or manipulated. Lack positional accuracy information and do not follow National Map Accuracy Standards. National Map Accuracy Standards are established for the federal government by the U.S. Geological Survey, http://mapping.usgs.gov/standards/ . Dams, Discharge Sites, Toxic Releases, and Industrial Sites (1) EPA needed to estimate flows for more than 60,000 reaches because it needed flow data on all RF1 reaches and the USGS had consistent streamflow data on fewer than 2,000 of them. Several other limitations and error sources of the RF1 database have been revealed and could be significant in some cases of modeling for TMDL development. Based on metadata compiled for the RF1 spatial database by the EPA ,an abbreviated list of spatial and temporal limitations is presented here: Data were needed at the downstream ends of the reaches rather than where the USGS gauges were typically located. All of the RF1 flow data for these locations are estimates. Vast areas of the country were without USGS data for drainage areas under 500 square miles. Approximately 4,000 gauges did not have useful flow data but were used to assign drainage area to reaches in RF1. 8 Because of data skew and anomalous conditions at many of these gauges, graphical techniques were applied to the solution of the mean annual and 7Q10 flow estimates at the gauged sites. Overall flow estimation methodology used in producing the RF1 flow estimates was not designed to produce accurate results on start reaches or small un-gauged tributaries, nor in estuaries or un-gauged coastal streams. Thus the accuracy of the flow estimates in these types of streams is not expected to be adequate for many applications. Factors such as irregular density of reaches in a particular area of a state or data problems within the period of record for a particular gauge, may introduce local variations in the accuracy of these flow estimates. The USGS Water Resources Division cautions users that since the RF1 flow estimates are provided at the downstream ends of gauged and un-gauged reaches and not at the actual gauge sites, these RF1 flow estimates may differ from USGS records at the gauge sites. Furthermore, the USGS Water Resources Division cautions users that these 1982 RF1 flow data are from EPA files and may not accurately represents current records of the USGS. Users of BASINS and its internal modeling capabilities would be well advised to seriously consider each of these limitations. Assessments developed with such limitations may not be considered reliable and may, therefore, be potentially disapproved by EPA for TMDL development. HSPF (BASINS/NPSM) CALIBRATION CAVEATS With nonpoint source models such as HSPF, simulated responses can have minor and major discrepancies to the observed records that are caused by slight “shifts” in the hydrologic response to precipitation events. These differences, by themselves, do not affect the efficacy of the calibration, but would result in large percentage differences if made in the same mode as a steady state model. Example HSPF calibrations are displayed in the two panels of Figure 2. The left panel depicts a near perfect calibration for a 145 day period. Simulated and observed output coincides for a wide range of conditions, with the model simulating nearly perfectly every storm event. The example in the right panel, however, represents a time period where individual storm events seemingly are captured in the simulation but appear a few days earlier than expected, suggesting an adjustment is needed in HSPF hydrology parameters that affect flow timing, rather than flow distribution. In many calibrations, however, both magnitude and timing differences occur that further confounds the calibration. Little formal guidance is available for calibrating complex water quality models such as HSPF. An expert system-style manual exists for calibrating the hydrology routines in HSPF (USGS, 1998b) and is based upon a logical progression from the annual average water balance to tracking individual storm events in the hydrographs and ascertaining that the partitioning between runoff, baseflow, and interflow are correctly modeled. Some discrepancies are to be expected since available precipitation as rainfall or snowfall may not be exactly captured by a weather-station gauge. The prediction of the timing of snowmelt is another equally uncertain 9 phenomenon where precise matching of simulated with observed runoff/quality may not be achievable. Figure 2 HSPF Hydrology Calibrations HSPF Calibration - Fitted HSPF Calibration - Problematic 350 Simulated 300 Volumetric Flow (CFS) Observed 250 200 150 100 50 Observed 250 200 150 100 50 Time (Days) 145 133 121 97 109 85 73 61 49 37 25 1 145 133 121 109 97 85 73 61 49 37 25 13 0 1 0 Simulated 300 13 Volumetric Flow (CFS) 350 Time (Days) FUTURE BASINS ENHANCEMENTS AND ADDITIONS The following (Table 2) represents this author’s best understanding of BASINS’ future inferred from technical meeting summaries, web page listings, and through direct email correspondence. Funding limitations and shifting agency priorities could alter these plans and preliminary schedules. Comments are provided as necessary that promotes the general constructive criticism theme of this paper. These future plans highlight the importance of the BASINS toolkit in watershed-scale assessments and specific plans the Agency has for improvements. Table 2. Features Provided in Current and Future Releases of BASINS. Version (Date) Possible Addition/ Change 1.0 (1996) Inaugural release of GIS-based assessment tool and modeling. 2.0 (1998) Updated point source loadings, STORET water observations, river reaches files (RF3), STATSGO soils, topography (digital elevation), ecoregions, fish and wildlife consumption advisories, shellfish contamination, Clean Water Needs Survey, watershed delineation and landuse reclassification utilities, HSPF postprocessing tools, full RCHRES module capabilities, and watershed report generation utility. 2.1 (2000) Replacing current NPSM interface with GenScn (an interactive USGS developed watershed modeling interface that facilitates generation and analysis of watershed management scenarios)(USGS, 1998b), and HSPF 12.0 that includes Special Actions, yield-based nutrient modeling, new 10 3.0 (2000) 4.0 (2001-) degree-day Snow module, and air deposition simulation. Also, several water quality linkages will be corrected from the NPSM interface. Discontinuing TOXIROUTE model option in lieu of full HSPF implementation. Choice of nonpoint model by adding SWAT (Soil Water Assessment Tool)(Arnold, et al, 1995), requiring users to purchase ArcView’s Spatial Analyst Extension to deal with raster data formats. Watershed delineation based upon 8-, 11-, and 14-digit predetermined watershed boundaries with the aid of a digital elevation model (DEM). HSPF 12.0 will be included with all the caveats noted for BASINS 2.1. Investigations underway on AQUATOX (Park, et al, 1999) to provide simulation capabilities for lake eutrophication, and river bioaccumulation processes. Work is also underway on the EFDC (Environmental Fluid Dynamic Code) model to deal with time varying 2D and 3D estuarine waterbodies and sediment fate and transport behavior. BASINS v3.0, expected in FY 2000, will provide the user with a choice of watershed models for nonpoint source assessment; the HSPF, version 12 and the Soil Water Assessment Tool (SWAT). For some the SWAT model (Arnold, et al, 1995) is ideally suited to predict the effects of land management and arose from the Department of Agriculture’s (USDA) substantial research centered at Texas A&M University. The ability to use USDA developed and supported modeling approaches in parallel with the EPA and USGS supported HSPF model should increase the comfort level of the agricultural community as the agency deals with agricultural nonpoint source dominated TMDLs. Enhancements to the watershed delineation tool will rely upon raster data and will require additional commercial software to be resident with BASINS. ArcView’s Spatial Analyst Extension (version 1.1), which currently sells for about $2000, will be required if use of SWAT is desired. Recognizing that some users may not be interested (or cannot afford) to purchase this extension, EPA also will be releasing BASINS v2.1, which will provide full functionality of HSPF v12.0 through the use of the USGS GenScn (Generation and Analysis of Model Simulation Scenarios), which will retain the look and feel of the current NPSM (USGS, 1998b). The features of NPSM are being coded into the GenScn to facilitate simulation scenarios and to analyze and compare results. The GenScn interface will provide full functionality of HSPF v12.0 to include: a simplified snow melt algorithm (i.e., degree day approach); modeling of land to land transfers, high water tables and surface ponding (wetlands), yield-based nutrient modeling, air deposition, and a BMP and reporting module. In addition, a file utility, called WDM Utility, will be added into GenScn to facilitate creation and modification of weather data and other time series data and a parameter database of values used in previously documented HSPF studies (HSParm). In versions beyond BASINS 3.0, the Agency is considering a lentic process model to deal with sediment contamination and associated tools to simulate sediment source loadings important to many TMDL assessments. This model should be capable of being configured in 1, 2, or 3dimensions and deal with tidal flows and circulation. EFDC (Hamrick, 1992), strongly linked to the Chesapeake Bay water quality model (CH3D) is a candidate because it can be used in these 11 complex hydraulic and water quality situations situations. EFDC is also being used to develop the Sediment Modeling Toolkit that may ultimately be incorporated into BASINS. A field scale model in envisioned that will allow natural resource managers to explore the effects of specific combinations of BMPs and land management practices on controlling NPS loadings to water bodies. In addition, the mixing zone model CORMIX (Cornell Mixing Zone Model and Expert System) (EPA, 1990) and the Storm Water Management Model (SWMM) (EPA, 1988) also may be added in future years to meet identified needs of a broad user community. These models (especially EFDC and SWMM) also have a steep-learning curve if they are to be used reliably. Similarly, AQUATOX is being evaluated as a general ecological risk model for assessing exposure to nutrients and toxic chemicals in aquatic ecosystems at several tropic levels. It evolved from the CLEAN model at RPI in the 1970s (Park, et al, 1999). Longer term still, EPA has noted that ESRI’s ArcView upgrade to version 4.0, due out in 2000, will dramatically change the structure of ArcView by removing support of ArcView’s scripting language, AVENUE, and amending it with the ability to interface with code written in Visual Basic or C. While BASINS 2.1/3.0 will continue to use AVENUE scripts, and thus require ArcView 3.x, the Agency is aware of ESRI’s commitment to ArcView 3.x until 2002/3. This move to a more fully integrated GIS and database system will provide much more flexibility to BASINS’ development in the long run. The watershed tool will evolve to a more component based architecture, so that users will need to install only the components required for their specific analysis needs, including their own legacy models. The Agency has indicated that the spatial database will also be continuously updated to the BASINS GIS download web page, as new information becomes available. While these data and other data may be packaged for public distribution, access via the Internet will continue to be a prime distribution mechanism. SUMMARY EPA is lauded for its foresight in creating the BASINS tool, but the work should not end with the creation. While the Agency should be responsible for model support issues, the affected private and public entities must also be critical and demand the continued application by all of good science and reasoned modeling judgment. Modeling, for all the new tools emerging in the 1990s, is still an ‘art’ that is done well by only a select few. This user base needs to expand if the challenges and visions of the Clean Water Act are to be achieved in the early 21 st Century. TMDL development need not be a contentious process when stakeholders meet early and often to resolve their differences toward a common good – the health of the watershed. Common sense, professional judgment, and caution must temper user zest and enthusiasm in using the tool. Early NCASI experience has revealed the temptation to become enthralled by the GIS technology because it is new and exciting and provides some powerful analysis and mapping capability. Many potential users are not experienced with GIS technology, but the philosophy of BASINS makes it readily usable by both inexperienced modelers and spatial analysts. This is good in the sense that more can be accomplished quicker with fewer personnel resources, but bad in the sense that modeling quality assurance may not be maintained without strong EPA oversight. Consistent, long-range system support and training must be maintained 12 by the Agency to insure that the laudable goals of BASINS are still achievable beyond a five or ten year time horizon. Readers are reminded that the QUAL2E model was the subject of frequent Agency training in the decades of the 1970s and 1980s through the CEAM in Athens, Georgia, but virtually disappeared in the 1990s. Senior Agency management needs to ensure that BASINS does not meet a similar fate. One can project that the Agency’s Watershed Initiative will preclude this unfortunate fate, but unforeseen congressional budget cuts could have a devastating effect. The Agency needs to facilitate public dialogue to apply political pressure to mandate consistent and sustainable support. Webster’s defines serendipity, as the ‘faculty of unexpectedly finding valuable or agreeable things not sought for’. While the Agency’s long-range goal for the BASINS tool may ultimately fit into this definition, there is an element of wishful thinking, or even naivete, in the current philosophy. In its zeal to create a new and useful tool for the overly litigious TMDL domain, EPA has overlooked some basic tenets of good science and modeling practice and may have placed a premium on speed at the expense of quality and scientific truth. James Greenfield of EPA succinctly discussed TMDLs at a recent conference by stating they can be cheap, fast, or accurate – pick any two (Georgia, 1999). This paper has suggested that ‘fast’ or ‘cheap’ at the expense of accuracy should not be acceptable. REFERENCES Arnold, J.G., J.R. Williams, and D.R. Maidment. 1995. A continuous-time watershed sediment routing model for large basins. ASCE J. Hydr. Eng. 142:47-69. Brown. L.C. and T.O. Barnwell, 1987. The Enhanced Stream Quality Models QUAL2E and QUAL2E-UNCAS: Documentation and Users Manual. EPA/600/3-87/007. Crawford, N. H. and R.K. Lindsey, 1976. Digital Simulation in Hydrology: The Stanford Watershed Model IV, Technical Report No. 39, Stanford University, Palo Alto, CA. Donigian, A. 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