HomeMy WebLinkAbout2022-11-18-SAC Meeting SummaryNC Nutrient Criteria Development Plan – Scientific Advisory Council (SAC)
11/18/2022
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Attendees
SAC members in attendance:
Jim Bowen
Jud Kenworthy
Jessie Jarvis
Martin Lebo
Lauren Petter
Michael O’Driscoll
Fritz Rohde
Wilson Laney
Rachel Gittman (in and out)
Hans Paerl
Marcelo Ardon
NCDEQ staff in attendance: Note: may not have captured all DEQ staff in attendance
Rich Gannon
Chris Ventaloro
Susie Meadows (note taker)
Pam Behm
Nora Deamer
Anne Deaton
Charlie Deaton
Timothy Ellis
Casey Knight
Karen Higgins
Paul Cough
Heather Jennings
Cam Mcnutt
Elizabeth Kountis
Bridget Shelton
Paul Wojoski
Others: Nathan Hall, Anne Coan, Clifton Bell, TJ Lynch, Andy McDaniels,
SAC meeting facilitator:
Emily Barrett
Meeting notes
***All questions, comments and answers are paraphrased***
1) Convene (Emily Barrett)
• DEQ/DWR introductions
• SAC introductions
2) Recap of the SAC Charter (Emily Barrett):
• Striving for Consensus.
• The path forward when there’s a difference of opinion.
• Jud has requested this charter presentation to be sent to the SAC members.
3) Overview of Surface Water Standards and Assessment (Chris V., Pam B.):
• Goals of WQS: to restore and maintain the chemical, physical and biological
integrity of the Nation’s waters as per the CWA.
• Components:
o Designated Uses: goals of the waterbody
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o Criteria: limits on pollution magnitude, duration & frequency.
o Antidegredation: framework to maintain water quality where standards are
already met.
• Criteria:
o Magnitude (numeric value/statement describing conditions appropriate to
protect the use)
o Duration (time period over which magnitude is considered).
o Frequency (how often magnitude/duration cannot be met without
impacting the use).
• Development of Criteria:
o Each criteria component based on scientific evidence indicating
appropriate conditions to support use (tox studies, bioassessments, field
studies/assessment, chemical properties, organism stressor-response info,
etc.).
o Examples of how this information forms the development of the criteria.
• Magnitude: aquatic tox data – adverse effects concentration,
chemical properties – environmental persistence.
• Duration: lab and field studies – chronic and acute exposure times.
• Frequency: organism stressor-response data – recovery time from
catastrophic events.
o More useful example is Clarity for SAV protection: water quality condition
(for aquatic life).
• Magnitude: taken info that’s been published, to come up with
either light attenuation of 13% & 22% or light extinction coefficient.
• Duration: looked at use of a median growing season based on
knowledge of the critical growth of the SAV.
• Frequency: based on discussion from the July SAC meeting, we’re
looking at any season with insufficient light can affect support &
recovery of SAV.
• Assessment of Standards (Pam B): What is water quality assessment?
o CWA required WQS implementation program
o Goal is to identify whether waters are meeting standards, whether data is
inconclusive or not meeting standards.
o Waters that aren’t meeting standards and don’t have a protection plan
already are placed in Category 5 (303d list) of the Integrated Report per the
NCDEQ 303d Listing & Delisting Methodology. Category 5 assessments
require development of a restoration plan (TMDL or Management
Strategy).
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• Integrated Report:
o List all assessed waters and assigned categories.
o Established by Sections 305(b) and 303(d) of the CWA.
o Not required to receive public comment on the report, but we do.
o Went over 305(b) integrated reporting categories: 1 is meeting criteria, 3 is
data inconclusive and 4 & 5 are exceeding the criteria/impaired.
• 303(d) list: list of impaired waters where TMDL action is needed, public review and
comment, due to EPA every even-numbered year on April 1 and EPA has final
approval authority.
• How is assessment made: water bodies split into assessments units based on
conditions, multiple years used, data includes (chemical, bio, physical, fish tissue,
swim advisories), multiple types of assessments used (numeric criteria, benthic &
fish community rating system, recreational criteria, shellfish growing areas, fish
tissue consumption).
• Example: Chlorophyll-a standard – not greater than 40 ug/l for lakes, reservoirs
and other waters subject to growths of macroscopic/microscopic vegetation.
o General assessment procedure: 5 yrs of data (min of 10 samples), applied
station by station, >10% exceedance with 90% statistical confidence
exceeding criteria = not meeting standards.
o Discussion about this being just an example and how the assessment is
different from the standard language.
• Clarity assessment development needs:
o Clear understanding of derivation of criteria number
o Clear understanding of uncertainties involved
o A monitoring plan to specify expected: sample locations, collection
frequency, sample numbers and procedures (QA/QC), any known or
expected challenges.
4) Draft 5 language for the Clarity (SAV) Standard: (Chris V.):
This is for Class SC waters. The same language can be used for Class C waters with the
removal of the high salinity component.
Clarity for Submerged Aquatic Vegetation (SAV):
(a) Low-salinity SAV waterbodies: not to exceed a SAV growing season median
photosynthetically active radiation (PAR) extinction coefficient (KdPAR) of 1.36 m-1.
(b) High-salinity SAV waterbodies: not to exceed a SAV growing season median
photosynthetically active radiation (PAR) extinction coefficient (KdPAR) of 0.89 m-1.
For the purpose of this Item:
(i) The SAV growing season is March 1 through October 31;
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(ii) Low and high salinity SAV waterbodies shall be those waterbodies identified as low or
high salinity SAV Regions in Table 4.5 and Figure 4.1 of Chapter Four of the Division of
Marine Fisheries North Carolina Coastal Habitat Protection Plan – 2021 Amendment
(CHPP), which is hereby incorporated by reference and can be obtained free of charge at
https://deq.nc.gov/media/26810/open;
(iii) The clarity standard for SAV shall apply only in those areas within SAV waterbodies
that currently have or historically have been vegetated with one or more of the following
species: bushy pondweed or southern naiad (Najas guadalupensis), coontail
(Ceratophyllum demersum), eelgrass (Zostera marina), horned pondweed (Zannichellia
palustris), naiads (Najas spp.), redhead grass (Potamogeton perfoliatus), sago pondweed
(Stuckenia pectinata, formerly Potamogeton pectinatus), shoalgrass (Halodule wrightii),
slender pondweed (Potamogeton pusillus), water stargrass (Heteranthera dubia), water
starwort (Callitriche heterophylla), waterweeds (Elodea spp.), widgeongrass (Ruppia
maritima), and wild celery (Vallisneria americana). These vegetated areas are documented
in Figures 4.1 through 4.9 of the CHPP and are geospatially depicted in the online map
titled NC Submerged Aquatic Vegetation Areas, which is available at www.xxx.deq.gov.
• Jud: To retain consistency between subsections 2 and 3, we could use a reference
point of chapter 4 of the CHPP instead of referencing the website. Because that
chapter includes the identification of the historical extent of SAV and both high
and low salinity in NC.
• Chris: the website, deq website will be to an interactive map.
• Martin: I’m good with all except the frequency.
• Chris: Is everyone good with the extinction coefficient and growing season?
• Rich: might be good to describe why we didn’t use the exact language of the CHPP.
• Chris: We discussed in the last meeting to go with the extinction coefficient rather
than going with the specific depths.
• Wilson: How is the depth captured in those extinction coefficients?
• Jud: As they’re stated 1.36 meter will get the amount of light necessary for the
threshold amount of light to a specific depth which is based on what we know
about the maximum depth of growth of the plants in our system. If you apply that
particular extinction coefficient, you’ll get x % of light reaching a certain depth in
the water. That’s what we’ve related to a maximum depth of growth. It’s spelled
out in the CHPP.
• Wilson: How would you measure that in the field? High salinity for example.
• Jud: Typically, with 2 light sensors placed at different depths, like 50 cm apart on a
pole and then you place sensors in the water and record the 2 light measurements
and then calculate the extinction coefficient between the 2. You could profile the
whole water column in certain increments.
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• Jesse: I can see Wilson’s point here, that it could be confusing not having the
required depth stated, so if you measuring kd out in the middle of the channel, but
do we need to be more explicit here?
• Chris: Keep in mind, that along with this standard language there will be a
monitoring plan/SOP on how to sample and where. It’s a next step discussion. We
wanted to keep the standard language simple.
• Wilson: What you said makes sense. If the assessment is explained in assessment
methodology/ SOP, I am good with that.
• Chris: We are wanting to have supporting documents to go along with the
standard.
• Wilson: the clarity standards are good for SAV and the predators using those beds.
• Chris: That info will be good for when we have to write up a fiscal note.
• Emily: Should the SAC members start gathering citations of work done?
• Chris: yes.
• Judd: one thing to address in the SOP, is where are these stations in relation to the
SAV beds.
• Rich: The description of SAV was decided to tie it into current or historic extent of
waters as mapped. We thought it was the cleanest and simplest way to do it.
• Lauren: Same list of species from the previous regulation, are there any species
left out?
• Anne D: That species list are the same as what’s in our rulebook, so it should be all
inclusive.
• Marcello: Might be too much in the weeds, but the extinction coefficients having
to be 1.36 or 0.89, what happens if in the assessment it comes out to 1.35 or 0.91?
• Cam: If the median value was that close, we’d likely say the data was inconclusive.
• Marcello: These numbers came from Nathan’s work, would values of 1.3 or 0.8
would be more easy to implement.
• Nathan: The numbers came from the work in the Chesapeake and where the
seagrasses can live.
• Cam: We probably need to be more conservative with the numbers.
• Chris: what if we round up? Like 1.4 and 0.9. I’m curious if the SAC is suggesting
that?
• Cam: How far off will it be from the 13% and 22% if we round?
• Wilson: Back to species list. There might be another Vallisneria out there, so we
will need to look at the list closer. Need to look into that more.
• Chris: Keep in mind that we review the standards every 3 years, so if there are new
species that pop up, we can add them to the list.
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• Lauren: The rounding idea, doesn’t sound good. It’s better to be precise on the
criteria.
• Cam: the difference here is the not to exceed median, we don’t have the extra
statistical confidence to put on whether we’re exceeding that.
• Lauren: I would suggest that if there was anything measurement error, we could
discuss it next time because there is specific language on it.
• Jesse: if you have secchi depth, you can translate to kd. There are equations out
there to do that.
• Nathan: Those don’t work well if you have a mix of CDOM and particles. There are
vast differences between those 2 extremes of absorption vs scattering causing
attenuation.
• Martin: Having an uncertainty around the measurement may allow a confidence of
how different it would be from say 1.36 and you have a frequency of not more
than 1 in 3 years, then if you are a little above 1.36, there is some forgiveness
around that.
• Judd: If we want to be conservative the number needs to go lower. Has anyone
planted Vallisneria in an attempt to develop a super plant (from FL)?
• Nathan: Heard about that.
• Wilson: We just need to know if there is an additional naturally occurring
Vallisneria in NC, if not then we’re good.
• Rich: With regards to CDOM, we refer to the maps of current and historic
locations, we wouldn’t include a natural conditions clause that could make it very
complicated getting it through rulemaking. Just wanted to share our logic on that.
5) Clarity Standard Walk-through (Rich):
• Magnitude – there is support for this.
• Duration – growing season. Is everyone comfortable with this? To note climate
change could alter this.
o Wilson: Has there been discussion of changes based on climate change?
Just to make sure everyone is aware it could change in the future.
o Karen: It is accounted for in the Triennial Review (every 3 years). This
would be a good item to document in a supplemental document or SAC
document. As we move forward, people will come and go, so it would be
important to have this documented.
• Season – Growing season median is the duration component.
• # of samples – Maybe we should put that off for a subsequent meeting.
• Frequency – We know there are issues with this and more discussion to have.
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• SAV not-definition – how do you like how we referenced this? Meaning species list
and maps. Is there support? Yes.
o Martin: I am not uncomfortable with the approach. Is there going to be any
provision in the assessment that, if someone believes the map incorrectly
reflects, can they petition?
o Chris: I don’t know. We haven’t talked about that.
o Cam: We would look at this on the assessment side and probably say data
is inconclusive.
o Karen: The way the language is written, it is not dynamic. It is referencing a
static map through the 2021 CHPP and if changes needed to be made that
would be done through the Triennial Review. The regulatory community
will have concerns if changes aren’t predictable and done through
rulemaking. So, that’s why worded it the way we did.
• Referencing maps for high/low salinity - yes
• Referencing maps for historic extent - yes
• Natural conditions clause – We are relying on current and historic extent, for what
is capturing any natural conditions that have prevented it from existing. Natural
conditions are also considered during the assessment process.
Is there support for this approach?
o Martin: Most of the of the natural conditions are addressed well by historic
range where the biology tells you where it has grown. You aren’t going to
have meteorological conditions frequently, but can cause water clarity
issues through DOM, turbidity. That could be covered through frequency if
you have a not to exceed.
o Lauren: A point for homework on the high and low salinity, is to look at that
table 4.5, the Cape Fear River to SC line region has high/low but also has 0
historic extent, so maybe it’s a non-issue, or maybe there should be an
extra line in there if you were to apply high/low. Just flagging that to
double-check the details.
o Emily: Do you think that would warrant clarification in words?
o Lauren: There could be a question at some point because that region is
included in the table 4.5, but it does say 0 historic extent, so that could be
documented.
o Jud: all state agencies signed off on the CHPP for special extent, we
shouldn’t doubt it.
o Anne D: I agree Judd, but the reason it’s there is b/c the recorded southern
limit is to the Cape Fear River, but we don’t go that documented in the map
because don’t historically go back that far. So, leaving the 0 extent is fine.
o Wilson: The general consensus based on discussions with the ASMFC
Habitat Community and South Atlantic Fisheries Management Council
Habitat Advisory Panel is that SC and Georgia don’t SAV because of the high
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tidal range and associated high turbidity. I think that generally applies to
the Lower Cape Fear River Estuary as well. So, appropriate to say 0 extent
and the map.
o Emily: I feel the SAC members understand Martin’s comment/question.
o Martin: I’d like to hear more. Not to exceed one in 3 yrs, more appropriate
and more protective of seagrass.
o Jim B: Can someone speak to the Chesapeake standard.
o Jesse: There is literature out there that shows if there is low light during
just one part of the growing season in the spring, that effects the entire
meadow and can result in increased mortality and loss of the meadow.
Seasonal light in one year can have big impacts on meadow-level response
and can result in loss of meadows. By looking at the entire growing season
and by using the median value, we are incorporating those light issues.
o Jim: By going with a seasonal median, there were more than one
measurements taken that year were above critical light attenuation and
that was enough to cause serious damage. By doing a seasonal median, we
are allowing for single excursions, but when the excursion is the rule,
then that’s when this standard is violated. Seems reasonable to me.
o Jud: There are a mix of species here, but fundamentally they’re all clonal
plants. There are also flowering plants that produce flowers and seeds.
Seeds are so important so if there is a loss of the process of flowering
during one growing season is a significant event. One season can have
serious and detrimental effect on them. So, waiting 3 years is dangerous.
It’s a risk to not look at them based on a seasonal median.
o Jim: Interested in what Clifton could tell us about the duration and
frequency in the Chesapeake’s criteria.
o Emily: We reserve this time to SAC members and DEQ members. Since a
SAC member requested this, we will let him speak.
o Clifton: The Chesapeake Bay standard was derived in a similar kind of way
with the exception of recognition of variability among segments in terms of
depth of application. On the assessment side it’s a 3 year assessment based
on the best single year. A 1 in 3 would be more stringent than the
Chesapeake Bay standard. Basically, it’s the reverse, you only have to meet
it one out of three. It was done because of the historical mosaic
recognized. It was not based on the idea that one year of light wouldn’t
cause the beds to recede. It’s based on inter-annual variability is somewhat
inevitable and that beds can recover. Also, because you base your standard
on a historical mosaic of the best year, trying to expect that 5 years in a
row isn’t a reasonable expectation. If you go without a frequency standard,
recognize this is a much more stringent standard than they’ve set up north
and I think there will be a lot of questions about that.
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o Emily: Clifton did you say the Chesapeake went with a not to exceed?
o Clifton: They went with a single best year approach out of three. So, a one
out three would be a compromise between expecting to meet your single
best year every year and ignoring inter-annual variability and the
Chesapeake approach.
o Emily: Lauren we would like your perspective.
Also, from a process standpoint, are we ready to say that we have
consensus with one dissenting opinion, we’d need to document.
o Lauren: I’m not familiar with the Chesapeake, but we should go with not to
exceed. 1 in 3 tends to follow more data rich data sets. At this point I’m
not hearing NC specific information that would make it be more like the
Chesapeake.
o Jud: Chesapeake Bay is still losing SAV, so keep that in mind. In practice,
we’ve segmented our system, high and low salinity, and in segmenting the
system even further is something we should be aware of down the road.
We have identified where losses are occurring at a greater rate than they
are in other areas. So, it could lead to further segmenting our high salinity
areas. I think we are moving in the right direction. We could do further
segmenting in the future.
o Emily: Are we comfortable moving forward with a consensus decision?
Marcello: good as written, Jim: good, Jesse: good, Jud: good, Martin: good
(but have concerns and would like them noted in a write-up), Michael:
good (should we have a definition of low and high salinity?), Hans: good,
Lauren: good, Fritz: good, Wilson: good.
6) Proposed SAC schedule/timeline going forward (Rich/Karen):
• Regrouping January and discuss the protocol for sampling. See how that impacts
duration, number of samples, so on.
• Keep moving forward with the written documentation for the SAC members to
review in March. That’s our goal.
• Jud is the current chair and can figure out how to get that written. Jud & Hans.
• Jud: Could you go over the parameters of that write-up?
• Chris: Scientific citations on the magnitude, duration, frequency. Brief and to the
point.
• Karen: Lauren, do you have thoughts?
• Lauren: Good news is a lot of it refers to the CHPP plan. Just hit the highlights of
why the language we said we’re okay with is okay, insert citations and other
references that we can respond to.
• Jud: So, we want this document to be drafted and reviewed and endorsed by the
full committee. Is that the plan?
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• Emily: Yes.
• Anne D.: At the WQC the Chair had an agreement to ask the EMC to instruct DWR
to continue to develop the standard with the SAC, get input from CIC, then go to
the EMC in March at the latest. So, from what I just heard, that would not be able
to happen.
• Karen: That was phrased as a goal, but we’re not quite there yet. It’s a goal. Your
concern is noted. And I don’t think we can move any faster than we are currently.
7) Next Steps (Emily Barrett):
• Next meeting is on Jan. 20, 2023 at 9am-12pm.
8) Closing (Emily Barrett)
9) Meeting Adjourned (Emily Barrett)