The State of Georgia’s Rivers, or Why Buffers Matter
There are more than 70,000 miles of streams, 425,000 acres of reservoirs and lakes, 400,000 acres of coastal marshlands, and 4.5 million acres of freshwater wetlands in Georgia. The Environmental Protection Division (EPD) assesses those waters every two years as required by the federal Clean Water Act (1972). The Clean Water Act’s goal is “to restore and maintain the chemical, physical, and biological integrity of the nation’s waters.”
Unfortunately, an analysis of data collected by EPD from 2006 to 2014 shows that there has been little overall improvement in river and stream health.
Every water body in Georgia has one (or more) designated use: fishing, drinking water supply, recreation, coastal fishing, wild river, or scenic river. Furthermore, each of those designated uses must meet specific water quality criteria (for dissolved oxygen, fecal coliform, metals, etc.).
Every two years EPD takes on the Herculean-effort to collect water quality data for a fraction—around 20 percent—of the total of all of Georgia’s rivers, streams, and lakes. EPD then produces a “305b Report” to describe the quality of Georgia’s waters. Waters on the 305b list that do not meet the water quality criteria for their designated use are placed onto the 303d list of “impaired waters.”
Once a water body is placed on the 303d list of impaired waters, EPD develops a total maximum daily load (TMDL) plan to create a strategy for restoring a water body’s quality and designated use. TMDL’s address the specific parameter(s) that caused water quality to degrade, like high fecal coliform concentrations, low dissolved oxygen, excess metals, and toxicity. Identifying point and non-point sources of individual pollutants is a critical component to maintaining and restoring high water quality and protecting designated uses.
Data collected from Georgia’s biannual 305b lists from 2006 to 2014 shows that there has been insignificant change in river and stream health. As illustrated in these pie charts, there is little variation in the percentage of waters that either meet or fall short of their designated use.
From 2006 to 2014 the total number of rivers and streams assessed increased from 1,734 to 2,297. While EPD assessed 32% more rivers and streams in 2014 over other years, regardless of the report year, the pie charts illustrate that over 50% of the assessed stream and river miles have not supported their designated use. In short, while some previously impaired water-bodies have been cleaned up, the same percentage of streams and rivers have been “impaired” for nearly a decade.
It is difficult to argue that TMDL’s are making a significant impact. The purpose of TMDL’s is to help responsible parties who are contributing to the impairment to resolve the situation by certain deadlines. This is only an effective strategy when pollution sources can be easily identified. So, EPD must write enforceable permits that meet Clean Water Act standards, particularly for known discharges into known impaired waters.
For example, permits for industrial land applications systems (LAS), such as TenCate’s in the Flint River basin, must be protective of water quality. Spring Creek, a tributary to the Flint in Upson County adjacent to TenCate’s operation, is currently not supporting its designated use for fishing. Rayonier Advanced Materials’ permitted discharge has historically sullied the Altamaha River. In these situations, EPD must write permits that fully protect Georgia’s streams and property owners.
Furthermore, EPD must ensure concentrated animal feeding operations are properly managing and land applying dry and wet manure in accordance with Georgia’s water quality rules.
The biggest problem, however, is resolving non-point source pollution—like agricultural, residential and storm water runoff. A TMDL is only as effective as its ability to identify the source of the impairment. TMDL’s are not comprehensive enough in addressing non-point source pollution. The over application of fertilizers—nitrates and phosphates—in residential and agricultural situations are classic examples of non-point sources. These pollutants inconspicuously enter our streams and contribute to water quality problems that affect designated uses.
Because non-point source pollution is a leading source of water quality impairment in Georgia, EPD argues that “the establishment and maintenance of vegetated riparian buffers is one of the most important and cost-effective” measures to protect “water quality” in Georgia. [Page 4-7]
We could not agree more with EPD. And so we ask the agency’s leadership to work with us to protect all of Georgia’s rivers and streams with riparian buffers, even those rivers and streams lacking “wrested vegetation.” All of these waters deserve equal protection.