I presume by now you’ve read Gary Minton’s guest editorial concerning stormwater characterization monitoring in the latest edition of Stormwater Magazine. I have to agree with Dr. Minton’s assessment of the inconsistencies and problems with such monitoring, but in most cases, that can be solved simply by establishing, even arbitrarily if need be, a standard method so that we are comparing apples to apples.
Concerning Dr. Minton’s suggested alternatives for monitoring, I can relate just as many problems and inconsistencies. Even something as seemingly straight-forward as sampling what goes into a BMP and what comes out of it is problematic since in most cases the hydrographs (frequency and duration of flows) into and out of the BMP are different. Simply analyzing the stuff that comes out of a drain inlet sump or street sweeper incorrectly assumes that every bit of the content on that stuff would have been released into the water column.
But my main reason for writing is to absolutely disagree with his suggestions for alternative monitoring methods. If a city (permittee) discharges into a body of water that, based on ambient monitoring, is impaired for, say nitrogen, and nothing else, then it doesn’t make sense to spend scarce resources sampling runoff sources, by any method, for a variety of other potential pollutants that don’t seem to be a problem. We need to keep our eye on the ball, and spend what limited resources we have on fixing impairment problems, not wasting them on irresponsible monitoring. I have repeatedly said that there isn’t enough money in the world to bring every impaired water body in the country back from impairment, and even more so than ever in these difficult times.
As long as comprehensive ambient monitoring discloses no problems with parameter X in receiving waters, then don’t make people spend their money looking for it in discharges. If at some time, parameter X begins to look like it may be increasing in the water body, then we have an opportunity to start looking for its source. Anything else is wasteful and irresponsible.
Thank you,
Don Moores Senior Environmental Scientist Applied Sciences Consulting, Inc.
