Related APHA Policy Statements
APHA Policy Statement 6315 – Public Health Aspects of Water Resources Management
APHA Policy Statement 6411 – Biodegradability of Products in Wastewater Streams
APHA Policy Statement 7021 – Principles for Environmental Protection
APHA Policy Statement 7435(PP) – The Management of Pesticides
APHA Policy Statement 8111 – Disposal of Hazardous Wastes
APHA Policy Statement 9206 – Toxic Reduction as a Means of Pollution Prevention
APHA Policy Statement 20037 – Precautionary Moratorium on New Concentrated Animal Feed Operations
Coastal waters are an invaluable source of food, employment, recreation, and habitat; they also provide a first defense against many natural and man-made hazards and disasters. Each year, dangerously high levels of pollutants enter the waters off the coast of the United States, threatening delicate ocean ecosystems and placing a disproportionate health burden on vulnerable populations. While legislation addressing water pollution has improved water quality throughout the United States over the last 40 years, current provisions are dated, underresourced, and unresponsive to modern and emerging sources of pollution. A multisectoral, watershed approach, combined with improved enforcement of current regulations and increased funding, is necessary to protect the public’s health and ensure the vitality of fragile ecosystems around the globe for generations to come.
Each year, dangerously high levels of pollutants enter the coastal waters of the United States. This pollution originates from human development and activity along all components of the coastal watershed system. These coastal waters are an invaluable source of food, employment, recreation, and habitat; they also provide a first defense against many natural and man-made hazards and disasters.1–3 While America’s waterways appear pristine, many, including such national treasures as the Chesapeake Bay and Puget Sound, are contaminated by toxic runoff and poisonous industrial discharge. This has dramatic consequences for human health and well-being, disproportionately affecting vulnerable communities as well as the fragile ecosystems that are home to many threatened aquatic and wildlife species.
Americans eat, on average, nearly 16 pounds of fish and shellfish per person each year.4 Populations that eat larger quantities of seafood, such as subsistence fishermen, low-income groups, many Asian American communities, and some Native American tribes, are disproportionately affected by contamination from coastal water pollution, specifically bioaccumulation of toxins in their seafood.5 Currently, insufficient mechanisms are in place for prevention and control of coastal watershed pollution. The major tool in place for prevention and control of water pollution, as well as restoration of contaminated watersheds, is the 1972 Clean Water Act (CWA). Although the CWA has improved water quality throughout the United States over the last 40 years, its provisions are dated, underresourced, and unresponsive to modern and emerging sources of pollution.6–8 APHA recognizes the impact of environmental health on human health and is issuing this policy resolution to solidify its stance on cleanup and prevention of pollution in coastal watersheds through legislative action.
Importance of coastal watersheds: Watersheds—vast inland areas including wetlands, rivers, streams, and estuaries—collect water and feed into coastal waters.5As a result, pollutants released into a small stream as far inland as Nebraska can be washed all the way out to sea. Humans rely on coastal waters for tourism and recreation, and industries related to transportation, fishing, mining, and utilities depend on coastal waters to support economic growth.9 Coastal counties are the most highly desirable and densely developed areas in the United States.10 Although coastal regions in the 48 contiguous states make up only 17% of the total country’s land area, they house 53% of the nation’s population and are projected to grow another 10% by 2020.11 This population growth threatens both the health of the water and the health of those living near it.
Clean water is essential for healthy people, a healthy economy, and a healthy environment. Coastal counties in the United States host 47 million jobs and contribute $5.6 trillion toward the nation’s gross domestic product (GDP), much of which is based on tourism and coastal industry.12 The National Resource Defense Council identified 24,091 US beach closures in 2010, representing the second highest level reported in 21 years.12,13 The country’s fisheries produced $4.5 billion in catches in 2010.11 Polluted coastal waters threaten the economic livelihood and the sustainable food sources of millions of Americans and contribute to disease and poor health outcomes through contamination of drinking water, consumption of tainted seafood, direct contact with polluted water sources, and ecological degradation. Vulnerable populations, including children, the elderly, and pregnant and breastfeeding women, are disproportionately affected due to their greater susceptibility to waterborne diseases and detrimental health effects from eating contaminated food. Illnesses associated with polluted coastal waters used for recreation include skin rashes, eye infections, respiratory infections, other infections such as hepatitis, and gastrointestinal illnesses.14
Threats to water quality: Human activities, both on our coasts and deep in our inland watersheds, continue to compromise coastal water quality. Due to inadequate management of environmental health and safety standards in recent decades and a lack of updated legislation, coastal watersheds are still vulnerable to multiple insults. Coastal waters in the United States have a tortuous history of toxic runoff and pollution.7,8,15–17 Although the CWA improved the health of coastal waters in the years following its implementation, it created a system primarily designed to address specific and definable point sources of pollution while failing to adequately address nonpoint sources of pollution, which account for a majority of the water pollution in the United States today18–21 Pollution causes widespread damage to the environment. Seven states—California, Indiana, Ohio, Michigan, Kentucky, Illinois, and Iowa—have lost more than 80% of their original wetlands, and an additional 22 states have lost more than 50%.17 Wetlands provide many benefits for humans, including flood control for coastal towns and cities, storm impact mitigation, erosion control, and sustenance for communities along coasts.22
Sources of pollution: Point sources of pollution are typically regulated as specific, identifiable sources from which pollutants are discharged. Industrial discharges include effluent emissions from paper mills, pulp mills, oil refineries, and manufacturing facilities. These discharges commonly contain mercury, lead, sulfur, oils, corrosives, nutrients such as nitrogen and phosphorous, and other toxic chemicals.23 Industrial pollutants are a significant contributing factor to problems in impaired estuaries whose water quality standards have dropped low enough to prohibit their intended use.4 Wastewater treatment plants, which process wastewater originating from household, manufacturing, and commercial activities, are also a major point source of pollution.24 Treatment plants remove most pathogens, organic materials, and suspended solids; however, certain nutrients—nitrogen and phosphorous, in particular—often remain in treatment plant discharge when tertiary treatment measures are not in place.23
Conversely, nonpoint source pollution cannot be traced to a single originating source, and is defined by the Environmental Protection Agency (EPA) as any water pollution that is not “point source” as legally defined by section 502(14) of the CWA.25,26 Today, nonpoint source pollution is responsible for more than 60% of water pollution in the United States,18 yet it is the target of only 3% of federal funding dedicated to control of water pollution.27 There is no comprehensive policy addressing nonpoint source pollution, and what exists is a patchwork of minimum control measures that are inconsistently enforced. The major causes of nonpoint source pollution are agriculture and forestry runoff, urban and stormwater runoff, air pollution, and changes to a water body’s physical structure and natural function, known as hydromodification.25 The majority of nonpoint source pollution affecting coastal waters is the result of runoff originating from multiple sources.28
Agricultural runoff is one of the leading sources of water pollution, yet the existing federal policy only minimally addresses the majority of agricultural activity in the United States.27 Among of the primary culprits of polluted agricultural runoff are animal feeding operations (AFOs), which produce waste containing high levels of nitrogen, phosphorous, heavy metals, and pharmaceutical agents.29 Very large AFOs—called concentrated animal feeding operations (CAFOs)—are regulated as point sources of pollution. However, CAFOs represent only 5% of AFOs in the United States, meaning that the remaining 95% of feeding operations go unregulated. In addition, many CAFOs escape regulation through legal loopholes. For example, poultry farms are considered CAFOs only if they are “wet systems” (a categorization that deals with the handling of manure), while the majority of poultry farms today are “dry operations.”29
Stormwater runoff also contributes significantly to nonpoint source pollution and is the leading source of toxic chemicals that wash into coastal waters.30Stormwater mixes with oil, grease, antifreeze, heavy metals, pesticides, fertilizers, and bacteria as it runs off roofs, over highways, and through yards, seeping into the ground and polluting streams, lakes, bays, and coastal waters.31 Stormwater runoff is largely unregulated except for combined sewers. Municipal stormwater systems that contain combined sewers are intended to collect rainwater runoff, domestic sewage, and industrial wastewater into a common pipe that transfers the combined waste to a sewage treatment plant.23,30,31 When total water volume entering the pipe overwhelms the capacity of the pipe or treatment plant, such as during a heavy rainfall or snowmelt, combined sewer system overflows escape without treatment.22 An estimated 40,000 sewage overflows occur annually, contributing to human health problems, closure of beaches and shell fishing areas, massive fish kills, and the decline of coral reefs.23 While municipal stormwater systems are regulated as a point source of pollution, effective management of stormwater runoff is difficult due to lack of funding and little enforcement oversight.32
Contemporary challenges: Modern insults to coastal waters further hinder comprehensive water protection efforts. Emerging pollutants such as phthalates, pharmaceuticals, pesticides, perfluorinated compounds, and personal care products have negative effects on human and aquatic health. This includes endocrine disruption, eggshell thinning, birth defects, and premature fish spawning.33 In addition, climate change is disrupting natural hydrological cycles including changed precipitation patterns, rising sea levels, and degraded water quality. Climate change alters stream flow and temperatures, damaging fish and wildlife habitats and threatening the health of communities that depend on them.34,35 Development patterns, particularly patterns of highly dispersed development, increase land-based activities and exacerbate runoff due to the widespread use of impervious surfaces 4 These surfaces, such as asphalt, concrete parking areas, roofs, and densely packed soil, prevent the ground from absorbing rainwater and its constituent pollutants.36 Land-based activities combine to contribute to 80% of pollution in coastal waters.37
Funding and regulation issues: Federal regulations require all point source polluters to obtain National Pollutant Discharge Elimination System (NPDES) permits. NPDES permit holders are directed to follow a series of “best management practices,” including public education and operational and maintenance procedures, in order to reduce pollutants “to the maximum extent practicable.”38 Due to inadequate staffing and unnecessarily complicated renewal applications, NPDES cannot adequately handle the volume of permits under its purview, thus allowing dangerous pollution levels to persist. Many permittees operate under expired, “administratively continued” permits, often for as long as 5 years.23,39
The severity of this problem is clear. Data compiled from EPA in 2009 revealed that polluters violated federal water quality standards more than 500,000 times. Currently, many industries factor in pollution fines as the “cost of doing business” and are not incentivized to change their operations to reduce or eliminate toxic discharge. Beyond paying fines, these industry polluters are not held accountable for the negative health consequences of their economic activities, resulting in an inequitable burden of pollution on certain communities, particularly minority, low-income, immigrant, and tribal communities.
Part of improving enforcement and regulation involves strengthening data collection and information sharing. The United States Government Accountability Office (GAO) and other agencies have documented this gap.41 For example, only one fifth of US rivers and streams have been evaluated for compliance with states’ water quality standards. Of those assessed, 39% were not in compliance.38 Given both the environmental consequences of water cleanup and the expense states incur to protect water quality, it is crucial that data from state agencies, federal agencies, volunteer groups, industries, academic researchers, and other parties be better coordinated.38
Congress has passed multiple policies addressing nonpoint source water pollution and watershed management, but participation is voluntary and funding is insufficient. This includes the creation of the Nonpoint Source Management Program,42 the National Estuary Program,43 and the Coastal Zone Act Reauthorization Amendments.44 They contain provisions for states to create pollution management plans, detail actions to protect at-risk estuaries, and implement a series of measures to reduce urban stormwater runoff. Due to inadequate enforcement, their voluntary nature, and limited funding, both NPDES and the aforementioned policies have failed to significantly decrease pollution in coastal watersheds. However, they present a useful model for the type of cooperative stakeholder involvement needed to address the multisectoral nature of watershed management.45,46 Through expansion, increased incentives, funding, and enforcement, these policies could provide a basis for more comprehensive and effective coastal watershed protections.
In order to tackle both point and nonpoint source pollution, and thus protect human and environmental health, greater intervention is needed at multiple levels. From federal regulation to community action, additional emphasis should be placed on protecting the most vulnerable populations that continue to be disproportionately affected by coastal water pollution.
Proposed Recommendations Statement
Progress on protecting our nation’s waters has stalled. Current regulations are insufficient, and better enforcement is needed to address the changing sources of water pollution. Federal policy has failed to meet its main goals of attaining zero discharge, maintaining fishable and swimmable waters, and preventing toxic pollutants from jeopardizing the health of our ecosystems.8
Advocacy by community members, activists, academics, government officials, and mass media over the past 50 years has been key to achieving gains in environmental health policy in the United States.47 APHA acknowledges these achievements and urges the United States to become an international leader in coastal water pollution cleanup and prevention. Updating legislation, improving enforcement, and employing an environmental justice lens will position the United States as a vanguard of coastal water and watershed conservation and offers a model for the international community. Failure to properly address the inadequacies of current policy and to improve management of the myriad sources of nonpoint water pollution will have devastating effects on our nation’s coastal waters, ecosystems, and the human life they support. Recognizing the burden of both point and nonpoint sources of water pollution on the environment and human health, APHA believes more stringent steps must be taken to prevent further damage. Accordingly, APHA supports modernization of federal policy and strengthening of comprehensive management of coastal water pollution through 4 mechanisms:
- Improving management of modern environmental insults to address emerging pollutants, failing infrastructure, climate change, and changing industrial operations.
- Strengthening the capacity of EPA to implement federal water quality rules, addressing such issues as deficient staffing and regulatory capacity.
- Strengthening national standards for the reduction of nonpoint source pollution through an emphasis on preventing runoff at the source and better financing mechanisms. This should include a management approach organized around watersheds with improved coordination between EPA and state and local governments on best management practices.
- Building capacity at the state and local levels to administer watershed protections, including the recognition of inequitable distribution of burden on vulnerable populations.
Pollution control decisions must incorporate up-to-date science, comply with the law, and protect downstream water users in other states. Efforts to decentralize federal policy and devolve enforcement of the CWA to the state level jeopardize the ability to ensure that pollution control decisions are made in such a manner. Some policymakers have argued that, rather than strict regulations, regulatory agencies and local stakeholders should create partnerships to increase effectiveness and prevent litigation.49 The CWA, at its roots, is a system of co-management between federal and state entities, with states maintaining primary implementation responsibilities for water pollution control.29 Most watersheds cross state lines, and while states appropriately have the lead role in implementing clean water protections, the CWA does not function effectively without national standards to account for this interstate nature of watersheds.50
In addition, some industry leaders, as well as many policy-makers, argue that complying with more stringent rules would be an undue cost burden to businesses. For example, laws limiting the construction of impermeable surfaces could prevent or increase the costs of new construction.51 Opponents of stricter regulations on animal feedlot operations—for instance, making plans for managing waste public—argue that public disclosure would reveal proprietary information, discouraging innovation in waste management and making animal feedlots vulnerable to lawsuits.29 In general, opponents of stricter environmental regulations define economically efficient regulations as those that do not hinder industry in favor of the environment.
Water quality trading programs are an emerging option to address water quality issues in the United States. Water quality trading is a voluntary exchange of pollutant reduction credits, meaning that a facility with a higher pollutant control cost can buy a pollutant reduction credit from a facility with a lower control cost. This reduces the cost of compliance for the facility with the higher overall pollutant control cost.52
In 2003 EPA established the Water Quality Trading Policy, which provides guidance for developing trading programs. However, EPA lacks regulatory power over trading programs. Water quality trading is a viable option if other means of pollution control, such as pollution prevention and implementation of new or improved technologies, are not effective.53 Water quality trading is a market-based tool predicated on discharge restrictions and costs that routinely disadvantage low-income and marginalized communities, limiting the possibility of achieving environmental justice and equity.
- Urges the federal government to reassert its authority for oversight of water quality standards, emphasizing a multisectoral approach (collaboration between such government entities as planning, transport, agriculture, and tourism) to coastal water protection and increasing oversight of minimum control measures taken by local communities to reduce runoff and combined sewer overflows.
- Urges the federal government, state governments, and municipal governments to incorporate stronger environmental justice policies and monitoring to reduce the impact of coastal water pollution on populations disproportionately affected by these pollutant sources.
- Supports EPA’s adoption of a coastal watershed approach to water quality and water quality protection with regard to both point and nonpoint source pollution.
- Urges Congress to fund major infrastructure improvements to wastewater treatment processing plants, enhance stormwater control measures to reduce sewage overflows, and implement tertiary treatment protocols.
- Urges Congress to allocate stronger federal funding for NPDES and create incentives for research and development of improved technology, in order to diminish coastal water pollution from agricultural runoff, more adequately treat wastewater and other industrial discharges, and improve ambient monitoring of pollution violators.
- Urges EPA to improve the implementation of the NPDES permitting program and eliminate the backlogging of applications for permits.
- Urges the federal government to strengthen regulation of runoff from concentrated animal feeding operations.
- Encourages states and municipalities to continue to establish more proactive nonpoint source management funding streams through fees on first possession of products that are known pollutants in stormwater runoff (petroleum products, pesticides, herbicides, and fertilizers) and fees by volume for stormwater runoff.
- Endorses the implementation by cities of low-impact development practices to minimize runoff, including the use of green infrastructure, captured stormwater redistribution, and protection of the natural hydrologic characteristics of land to achieve better surface water filtration.
- American Public Health Association. Advocacy & policy: policy statements. Available at: http://www.apha.org/advocacy/policy/. Accessed November 2, 2011.
- US Environmental Protection Agency, Office of Water. Oceans, coasts, estuaries and beaches. 2011. Available at: http://water.epa.gov/type/oceb/. Accessed November 7, 2011.
- Stewart JR, Gast RJ, Fujioka RS, et al. The coastal environment and human health: microbial indicators, pathogens, sentinels and reservoirs. Environ Health. 2008;7(suppl 2):S3.
- US Environmental Protection Agency. Report on the environment: coastal water. Available at: http://cfpub.epa.gov/eroe/index.cfm?fuseaction=list.listBySubTopic&ch=47&s=274. Accessed November 5, 2011.
- Conservation International. The ocean. Available at: http://www.conservation.org/where/oceans/Pages/overview.aspx. Accessed November 7, 2011.
- Andreen WL. Water quality today—has the Clean Water Act been a success? Ala Law Rev. 2004;55:537–593.
- Copeland C. Water Quality: Implementing the Clean Water Act. Washington, DC: Congressional Research Service; 2006.
- Malloy BA. Testing cooperative federalism: water quality standards under the Clean Water Act. Environ Energy Law Policy J. 2011;6(1):63–103.
- National Oceanic and Atmospheric Administration. Economic statistics for NOAA. Available at: http://www.publicaffairs.noaa.gov/pdf/economic-statistics2005.pdf. Accessed November 5, 2011.
- Crosset M, Culliton T, Wiley P, Goodspeed T. Population trends along the coastal United States: 1980–2008. Available at: http://oceanservice.noaa.gov/programs/mb/pdfs/coastal_pop_trends_complete.pdf. Accessed November 5, 2011.
- National Oceanic and Atmospheric Administration. NOAA’s State of the Coast. Available at: http://stateofthecoast.noaa.gov/population/welcome.html. Accessed November 5, 2011.
- Devine J. The Impacts of Beach Pollution. New York, NY: National Resources Defense Council; 2011.
- Dorfman M, Rosselot K. Testing the Waters. New York, NY: National Resources Defense Council; 2011.
- Griffin DW, Donaldson KA, Paul JH, Rose JB. Pathogenic human viruses in coastal waters. Clin Microbiol Rev. 2003;16(1):129–143.
- US Environmental Protection Agency. National coastal condition report II. Available at: http://www.epa.gov/owow/oceans/nccr/2005/index.html. Accessed November 5, 2011.
- US Environmental Protection Agency. Coastal watershed factsheets—oceans and coastal protection: your coastal watershed. Available at: http://water.epa.gov/type/oceb/fact1.cfm. Accessed November 5, 2011.
- Kraft M. Environmental Policy and Politics. 4th ed. Green Bay, WI: Pearson Longman; 2007.
- Migliaccio K, Li Y, Obreza T. Evolution of water quality regulations in the United States and Florida. Available at: http://edis.ifas.ufl.edu/ae431. Accessed November 5, 2011.
- Federal Water Pollution Control Act. 33 USC §101 (2002).
- US Environmental Protection Agency, Watershed Academy Web. Introduction to the Clean Water Act. Available at: http://www.epa.gov/owow/watershed/wacademy/acad2000/cwa/index.htm. Accessed November 5, 2011.
- US Environmental Protection Agency. The National Water Quality Inventory: report to Congress for the 2004 reporting cycle. Available at: http://water.epa.gov/lawsregs/guidance/cwa/305b/2004report_index.cfm. Accessed November 5, 2011.
- Vergara W. Environment Matters Annual Review. Washington, DC: World Bank; 2008.
- US Commission on Ocean Policy. Addressing coastal water pollution. Available at: http://www.oceancommission.gov/. Accessed November 6, 2011.
- National Oceanic and Atmospheric Administration. Coastal waters. Available at: http://forecast.weather.gov/glossary.php?word=coastal%20waters. Accessed November 2, 2011.
- US Environmental Protection Agency. What is nonpoint source pollution? Available at: http://water.epa.gov/polwaste/nps/whatis.cfm. Accessed October 31, 2011.
- Clean Water Act, Section 319: Nonpoint Source Management Programs, 33 USC §1329 (1987).
- Democratic Staff of the Committee on Transportation and Infrastructure. The Clean Water Act: 30 Years of Success in Peril. Washington, DC: US Congress; 2002.
- Natural Resources Defense Council. Rooftops to rivers: green strategies for controlling stormwater and combined sewer overflows. Available at: http://www.nrdc.org/water/pollution/rooftops/rooftops.pdf.Accessed November 1, 2011.
- Copeland C. Animal Waste and Water Quality: EPA Regulation of Concentrated Animal Feeding Operations. Washington, DC: Congressional Research Service; 2010.
- Sightline Institute. How to talk about polluted stormwater. Available at: http://daily.sightline.org/files/downloads/2012/05/stormwater-messaging.pdf.Accessed November 7, 2011.
- US Environmental Protection Agency. Combined sewage overflows. Available at: http://cfpub.epa.gov/npdes/home.cfm?program_id=5. Accessed November 1, 2011.
- Tibbetts J. Combined sewer systems: down, dirty, and out of date. Environ Health Perspect. 2005;113(7):A464–A467.
- Smith D. Emerging pollutants of concern: a survey of state activities and future needs. Available at: http://www.sawpa.org/documents/EC-Appendix-F.pdf. Accessed November 7, 2011.
- Water Environment Federation. Protecting water resources and infrastructure from the impacts of climate change. Available at: http://www.wef.org/GovernmentAffairs/PolicyPositionStatement/ProtectingWRClimateChange/. Accessed November 4, 2011.
- National Wildlife Federation. Puget Sound. Available at: http://www.nwf.org/Wildlife/Wild-Places/Puget-Sound.aspx. Accessed October 25, 2011.
- Dwight RH, Semenza JC, Baker DB. Association of urban runoff with coastal water quality in Orange County, California. Water Environ Res. 2002;74(1):82–90.
- Osborn D. Policy Cocktails for Protecting Coastal Waters From Land-Based Activities. Nairobi, Kenya: United Nations Environment Programme, Ecosystem Management Programme; 2011.
- Clean Water Act, Section 402: Nonpoint Source Management Programs, 33 USC §1342 (1987).
- National Pollutant Discharge Elimination System. NPDES frequently asked questions. Available at: http://cfpub.epa.gov/npdes/allfaqs.cfm?program_id=0. Accessed November 2, 2011.
- Duhigg C. Clean water laws are neglected, at a cost in suffering. Available at: http://www.nytimes.com/2009/09/13/us/13water.html?pagewanted=1&sq=Duhigg,%20Charles&st=cse&scp=3. Accessed October 29, 2011.
- United States Government Accountability Office. Watershed management: better coordination of data collection efforts needed to support key decisions. Available at: http://www.gao.gov/new.items/d04382.pdf. Accessed May 31, 2012.
- Clean Water Act, Section 320: Nonpoint Source Management Program, 33 USC §1330 (1987).
- Clean Water Act, Section 320: National Estuary Program, 33 USC §1330 (1987).
- Coastal Zone Management Act, Section 319: Coastal Zone Act Reauthorization Amendments, 16 USC §1455b (1990).
- Lubell M. Resolving conflict and building cooperation in the National Estuary Program. Environ Manag. 2004;33(5):677–691.
- Schneider M, Scholz J, Lubell M, Mindruta D, Edwardsen M. Building consensual institutions: networks and the National Estuary Program. Am J Pol Sci. 2003;47(1):143–158.
- Rhodes EL. Environmental Justice in America: A New Paradigm. Bloomington, IN: Indiana University Press; 2003.
- Executive Office of the President. Statement of Administration Policy. Washington, DC: Office of Management and Budget; 2011.
- Republican Platform: Environmental Protection. GOP Platform Statements. Washington, DC: Republican National Committee; 2008.
- Saks JGC, Jan HR. 2018: A Brazen Attack on Clean Water. Washington, DC: National Wildlife Federation; 2011.
- Glenna LL. Value-laden technocratic management and environmental conflicts: the case of the New York City watershed controversy. Sci Technol Human Values. 2010;35(81):81–112.
- US Environmental Protection Agency. Frequently asked questions about water quality trading. Available at: http://water.epa.gov/type/watersheds/trading/tradingfaq.cfm. Accessed November 6, 2011.
- US Environmental Protection Agency. National Pollutant Discharge Elimination System: water quality trading training. Available at: http://cfpub1.epa.gov/npdes/wqtraining.cfm. Accessed November 6, 2011.
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