Why ORSANCO’s Recreational Use Criteria Should be Updated in October 2012

1. Why ORSANCO’s Recreational Use Criteria Should be Updated in October 2012 ORSANCO POTW Advisory Committee Presentation to ORSANCO’s Technical Committee October 11-12, 2011 Washington, DC

2. What are we recommending? • Adopt new recreational uses (and assessment procedures) in October 2012 • Focus on E. coli • Recreation season geometric mean • Statistical threshold value of 25% instead of the “single-sample” maximum • Temporary use suspension for the Ohio River (based on stage)

3. Perspective on EPA’s Current Thinking on Recreational Use Criteria • Commend EPA’s efforts to develop new recreational use criteria for coastal waters & Great Lakes beaches • Support their efforts to make the 1986 criteria consistent with today’s understanding of past and present epidemiological-microbiological studies • Recognize a need to help EPA evaluate options for inland waters • Especially working rivers Picture of a Great Lakes beach photo of a barge chugging up the Ohio River with a downtown urban area and some bridges in the background.

4. Why Update ORSANCO’s Standards? • Consistent with current science • We need to target scarce resources to protect recreational uses, when the uses are actually occurring • Avoid wasting money on pollution controls that provide little or no public health or environmental benefits • We have a better understanding of the river now than when changes were first proposed • More data • More investment in protecting WQ by Utilities • More public understanding

5. Why Update ORSANCO’s Standards?(2) • Targeting scarce resources • Prioritization of controls (Consent Decrees, TMDLs, MS4 programs, nonpoint sources) • Consistent with goals of managing runoff with green infrastructure (target smaller storms first) • Avoiding wasting money by establishing realistic endpoints for • Already costly CSO/SSO Consent Decrees • A 980-mile bacteria TMDL for the Ohio River • Future TMDLs for XX tributaries to the Ohio River • Aligning standards with understanding about actual recreational activities and river conditions

6. Load duration curve graphic with pictures of the river at low, medium, and high flows • Emphasize that the proposed temporary suspension of recreational uses at the highest flows allows re-direction of pollution control efforts at the lower flows

7. Map of Ohio River with statistics on miles along the mainstem and stream miles of tributaries (by state) • Purpose is to shock the audience with the idea that if the mainstem bacteria TMDL is targeted at protecting ALL flow ranges, then each state will have to do this on each tributary (regardless of whether it is feasible or not!) • Include dots for all the CSO communities in the Ohio River basin for next slide

8. Why do POTWs Care? • Rate increases • Some statement of range • An extreme example • Program implementation costs for CSO/SSO control • Statement of range • An extreme example • Future costs • Failing infrastructure, MS4, nutrient removal, emerging contaminants • Fiduciary responsibility to customers

9. What have POTWs been doing? • Public education • Stakeholder groups • Watershed characterization and linking sources with water quality impacts • Monitoring data • Collection system models • Watershed & water quality models • Constructing controls • Partnering with NGOs • Developing recreational use tools

10. What are Cities Doing? • Facing tough choices because of economic environment • Examples of layoffs, etc. • Statement of how CWA compliance costs have sky-rocketed • Local Mayors’ initiatives • “Perfect Storm” CSO Communities Summit • Lima, OH effort • US Conference of Mayors’ initiatives • Dialog with EPA/DOJ headquarters on CSO/SSO Consent Decrees • Dialog with EPA on integration of wastewater, stormwater, and drinking water programs linked with cost/benefit and affordability • Need to also clear this with Fred Andes, B&T (Mayor Berger, City of Lima); and Rich Anderson, USCM

11. Why Change the Standards? • ORSANCO’s standards are not consistent with EPA clarifications on how the existing criteria and should be applied or their current thinking on new criteria • EPA’s new criteria have been developed for beaches and coastal waters • But, EPA intends to publish them for inland waters • Recreational uses on the Ohio River are different • Environmental conditions are different Same low flow conditions Same medium flow conditions Same high flow conditions

12. Why October 2012? • Good time to rally support by Cities and POTW ratepayers for getting the science right • Utilities committed to continuing public educational efforts around this issue • Provides realistic endpoints for TMDLs and long-term control plans • Celebrate success with achievable implementation plans! • Fosters targeting resources at controls that provide the most benefit

13. Thank You! • Mike Apgar (contact) • MaryLynn Lodor (contact) • List of all POTW Advisory Committee Members Background is a faded map of the cities and tributaries