Regulatory Interface Services
The interface between science and policy is key to applying regulatory guidelines in making appropriate site-specific decisions. Nautilus has an impressive history of effective interface between dischargers and regulatory agencies, including modifying existing regulations, developing site-specific criteria (e.g. Water-Effect Ratios), and performing risk assessments to aid in the decision-making process. In many cases, support for site-specific applications of regulations involves integration of toxicity, chemistry, and bioassessment information in order to provide a complete picture that fully justifies the proposed alternative. Thus, a science-based approach is generally the most effective in terms of maintaining credibility with the regulators, as well as providing a fundamentally sound basis for discussion.
One example of effective interface between regulatory agencies and dischargers follows:
California's Enclosed Bays and Estuaries policy calls for the phasing out of discharges into enclosed bays and estuaries unless there is a demonstration that there is a net benefit related to the discharge. Nautilus is working with a municipality that discharges treated wastewater into an estuary to characterize benefits associated with the discharge. The study involves a hydrology component to characterize the extent to which flows from the discharge replace flows that have been appropriated for uses upstream, an investigation of sediment and water contaminant levels to evaluate the extent to which the discharge may be affecting environmental quality, an investigation of sediment and aquatic toxicity to determine if there is toxicity (and whether it is related to the discharge), and an evaluation of ecological conditions to determine the extent to which the discharge may be affecting habitat in the estuary, as well as species of regulatory concern that may be present. The study has just bbeen completed and the initial response from the agencies has been favorable; of particular importance to the overall approach has been a study design that enables inputs from the effluent to be separated from other sources as potential causes of contaminant accumulation and/or toxicity. Thus, determining that the effluent is not degrading water quality in the lagoon is key to allowing the discussion to focus on its benefits in terms of providing replacement flows, habitat for key species, and improved water quality compared with groundwater, agricultural, and urban inputs to the lagoon. As part of this study, a WER was conducted that demonstrated that the water quality criterion for copper could be increased, based on site specific influences on bioavailability.