COLORADO MONITORING FRAMEWORK
NUTRIENT WORKSHOP
BROWN AND CALDWELL
1527 Cole Blvd, Suite 300, Lakewood
Crestone Training Room
March 17, 2015
9:00 a.m. – 2:30 p.m.
AGENDA
1. Setting the Stage (Reeves, Johnson, and Mesloh)
2. WQCD Statewide Nutrient Approach and Coordination with CLEAN (Ross)
3. Break
4. NACWA’s Review of Nutrient Permitting Methods (Bell)
5. Breakout Session – Prioritizing Alternatives
6. Lunch
7. South Platte Segment 15 Nutrient Model (Lewis)
8. WERF Nutrient Modeling Toolbox – Boulder Creek (Bell and Linenfelser)
9. Opportunities for WERF Next Steps (Linenfelser)
10. Breakout Session – Developing Action Plan
11. Wrap Up
12. Adjourn
COLORADO MONITORING FRAMEWORK
NUTRIENT WORKSHOP
BROWN AND CALDWELL
1527 Cole Blvd, Suite 300, Lakewood
Crestone Training Room
March 17, 2015
9:00 a.m. – 2:30 p.m.
Workshop Outcomes
The CMF Nutrient Workshop aims to achieve the following goals:
1. Reinvigorate CMF commitment to leading the development of flexible and attainable
alternatives to Regulation 31.
2. Understand the Division’s vision for using Regulation 85 data to implement Regulation 31
standards.
3. Prioritize tools/approaches to achieve an alternative to the interim values in Regulation 31.
4. Draft a schedule and actions to develop a flexible nutrient implementation/policy framework.
COLORADO MONITORING FRAMEWORK
NUTRIENT WORKSHOP
BROWN AND CALDWELL
1527 Cole Blvd, Suite 300, Lakewood
Crestone Training Room
March 17, 2015
9:00 a.m. – 2:30 p.m.
2014 Nutrient Workshop Breakout Results
1. Objective: What do you want/need from a site-specific standard?
Based on responses, we would like site-specific standards to:
a) Consider impacts on aquatic biota including a bioassessment of protected species
and identifying the impacts to MMI from different stressors.
b) Develop standards collaboratively and with a collaborative approach
c) Be innovative
d) Use sound, defensible science that uses supportable data, is accurate, is
appropriate, and produces limits that accurately reflect stream conditions.
e) Consider net environmental benefit and produce attainable goals that include an
understanding and justification for WWTP costs
f) Identify the critical condition for setting standards and set standards to protect that
critical condition include the modeling of extreme (variable) conditions
g) Provide certainty for permit setting
h) Understand how far downstream we must track nutrient impacts including nearfield
and farfield impacts, inputs and processes that occur downstream, and the
boundaries of the model used.
i) Identify and quantify sources and loads and the impacts of these loads.
j) Allow for trading and the ability to trade with other point source and nonpoint source
dischargers
k) Develop standards with trading goals in mind
l) Differentiate TN and TP limits
2. Goals: From your perspective as a stakeholder, how would you rank the importance of the
following potential drivers of water body specific nutrient modeling?
Based on responses, here is our list of priorities (from most important to least important):
1) Technical accuracy – avoid overprotective or underprotective criteria and limites
2) Realism – avoid setting unattainable or unaffordable goals for water bodies
3) Public Confidence – demonstrate to rate payers and public what they are getting for
their investment
4) Equity – Ensure that all major sources are identified and quantified
5) Controlling nutrients – determine if one nutrient can be controlled preferentially to
attain designated uses
6) Trading – provide a framework to reduce overall costs by trading/offsets
Additional drivers include:
a) Regulatory confidence (related to public confidence)
b) EPA/stakeholder trust
c) Climate change anticipation
d) Loading sensitivity (related to technical accuracy)
e) Effect of agricultural diversions
f) Sensitivity to changes like climate and flow (related to technical accuracy)
3. Barriers: What technical, regulatory, or economic barriers exist to water body-specific nutrient
modeling? What concerns might you or other stakeholders have about this approach?
Based on responses, our major barriers are:
a) The costs related to nutrient treatment are not proportional to stream improvement,
especially when hitting very low levels of nutrients.
b) The extent to which we have to model to meet the “farfield” requirements may cause
us to model on a very large scale. We need to confidently define farfield and
nearfield, keeping in mind that watersheds are not closed systems
c) Environmental groups who are not involved in the development of the standards
could make the process difficult/costly.
d) It will cost a lot of money to collect data and perform modeling necessary to get sitespecific standards and it is challenging to source money for this effort.
e) Water rights and our water management system could be a controlling factor in
meeting nutrient numbers.
f) At the large scale needed to address farfield effects, it may be difficult to utilize the
model to develop standards/permits for smaller reaches without significant cost.
g) It may be difficult to get buy-in for a nutrient model from EPA/Division.
h) Models being used by the Division or other models may be at odds with the models
we develop.
i) There is a lack of planning and transparency on the part of the regulators that could
make it difficult to develop acceptable site-specific standards.
j) If EPA does not participate, we may be in the dark about what are requiring. We need
to understand the purpose behind a nutrient model and consider EPA’s intentions
and standards.
k) Modeling could result in more stringent nutrient numbers.
4. Solutions: How might some of the barriers identified above be overcome?
Based on responses, possible solutions are:
a) Group models according to water body type.
b) Coordinate and collaborate between stakeholders, the Division, and EPA. Be
cooperative in communicating, exchanging knowledge, combining modelling efforts.
c) Develop site-specific standards and nutrient model on a pilot scale first.
d) Understand how the models relate to the Division’s MMI approach.
e) Collect quality data that can be used to effectively model through creating standard
data collection procedures
f) Focus on improving interactions between regulators and regulated entities.