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Critical Assessment of EPA's Weight-of-Evidence Approach to Nutrient Criteria Development

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EPA has developed a series of nutrient TMDLs for southeastern Pennsylvania watersheds that rely on a new method to establish nutrient criteria for phosphorus. This method, the weight-of-evidence approach, is not based on cause and effect relationships. Rather, it depends upon a collection of evaluations with dubious ties to nutrient-related use impairments. These “lines of evidence” were then used to establish a target endpoint for the TMDL based on a less than transparent weighting process. A critical review of the evidence used in this approach indicates that the selected endpoints are unlikely to result in designated use restoration. A review of sitespecific data for several of the affected watersheds confirms that the selected endpoints are inappropriate as other factors are responsible for the impairment.

Keywords: Conditional Probability Analysis; Macroinvertebrates; Nuisance Algal Growth; Nutrients; Phosphorus; TMDL; Water Quality Standard; Weight of Evidence

Document Type: Research Article


Publication date: 2009-01-01

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