What is 'triennial review,' and what does it have to do with your favorite stream, lake, or river?

The Missouri Department of Natural Resources has released a survey that’s very important, and a little bit wonky. It’s about a process called triennial review. This process is critical to protecting the health of our rivers, lakes and streams, but it’s not exactly straightforward. This post will give you the knowledge you need to understand DNR’s survey and share your priorities for Missouri’s waters.

Triennial Review and Water Quality

Every three years, each state must review its water quality standards. These standards define when water bodies are considered “impaired.” Most lakes, rivers, and streams in Missouri are subject to these standards, so triennial review probably impacts your favorite place to swim, fish, or paddle. 

Whether a water body is impaired depends on what people use it for (i.e., fishing, swimming, drinking) and what the acceptable levels of specific pollutants are for that specific use. By looking at how we use a lake, river, or stream, and then setting pollution limits based on that “designated use,” we can help ensure water is swimmable, drinkable or fishable. 

The pollution limits set by these criteria usually come in the form of a concentration, expressed in milligrams per liter. These limits are the product of scientific studies to determine the impacts of specific pollutants on human and environmental health. The results of these studies are incorporated into EPA’s “304(a) criteria.” These criteria represent scientifically sound baseline limits designed to protect human and environmental health. 

Because each water body is different, these 304(a) criteria aren’t hard and fast rules. What works to protect most fish in one river might not be enough to protect a specific species of fish in another. What works to prevent algal blooms in a wet and humid environment might not work in an area with less rainfall. Similarly, states might have different pollution issues. A state like Missouri, with a lot of coal-fired power plants, might have problems with mercury in fish tissue that other states don’t. The flexible nature of water quality standards and designated uses allows states to address their unique issues. 

The Designated Use Alphabet Soup

Water quality standards also depend upon what a waterbody’s designated use is. For example, if a water body is a public drinking water source, we’re going to be more concerned about pollutants that might impact human health. 

Question 2 refers to Ammonia limits for waters whose designated use is “AQL,” or aquatic life protection. This basically means that a waterbody can’t have so much pollution in it that it’s killing fish, mussels, or other things that live in it. It’s also the lowest standard a waterbody has to meet. 

Question 4 refers to “WBC” and “SCR,” whole body contact and secondary contact recreation. Whole body contact is exactly what it sounds like – swimming. Secondary contact recreation includes things like paddling, boating, or in-stream fishing. Human health protection criteria address pollution in fish tissue, helping to make sure you can eat what you catch. 

These designated uses determine how many water bodies proposed water quality standards will cover. AQL criteria will impact virtually every waterbody in the state. SCR, WBC, and HHP will cover fewer waterbodies, but will be more protective of those waters. 

Waterbodies that aren’t meeting water quality standards are placed on the 303(d) list, which requires DNR to develop a Total Maximum Daily Load (TMDL) often referred to as a pollution diet. TMDLs are intended to help solve water quality problems and eventually make a waterbody clean enough for its designated use.

My Two Cents

Hopefully the information above has helped clarify how the triennial review process works and made this survey a little easier to understand. I’m going to leave you with some thoughts about how I’m filling out this survey. 

Question 8, regarding Numeric Nutrient Criteria for Aquatic Life Protection in rivers and streams, is the most important among these, hands down. As mentioned above, most of these water quality standards are based on concentrations of pollutants. But right now, Missouri’s nutrient criteria has no numerical threshold. This means DNR, Stream Teams, or Waterkeeper can’t simply take a water sample, get it analyzed and have a definitive answer to whether a stream is impaired. This makes it more difficult for citizens to know what’s going on in their own backyards. It also makes it more difficult to control nutrient pollution, an enormous contributor to poor water quality in our state. The only drawback is this standard would only apply to rivers and streams, not lakes or reservoirs.

Question 4, setting bacteria and pathogen criteria for recreational bodies of water is also critically important. Pathogens and bacteria are often closely related to nutrient pollution, and can pose a real threat to human and animal health. We’ve already seen pets sickened this summer by swimming in lakes in neighboring states. Beaches in Missouri state parks are frequently closed due to high levels of pathogens. We should all be confident that wherever our favorite swimming hole is, it’s safe to take a dip. I’m going to be rating this one fairly high as well.

Several questions might have caught your attention specifically because they don’t reference existing 304(a) recommendations. Question 5 asks about dissolved oxygen standards in the Bootheel. This seems to be an effort to reduce water quality protections for streams in the Bootheel. Less dissolved oxygen means less healthy fish and mussels, and I’m going to be giving this a “zero” priority. 

Question 10 is about revisions to the Missouri Use Designated Dataset, charmingly referred to as the MUDD. The MUDD is the source of much of DNR’s information about where waterbodies are located and how they are classified. Making this dataset more accurate will make DNR’s decision making process more effective. This is especially true because many smaller streams lack use designations. I would rate this one fairly high on my list.

Question 11 is about tiered aquatic life criteria for headwater streams. Headwater streams make up the majority of stream miles in the United States and are some of the most sensitive and important habitat for aquatic species. I’m rating this one fairly high as well.

Of course, all the questions on the survey deserve your attention, and in a better world, where DNR was adequately funded, we wouldn’t have to choose between prioritizing one pollutant over another, or fishable waters over swimmable waters. I encourage you to look into the pollution problems in your own backyard and determine what issues are most important to you. The best thing all of us can do to improve water quality in Missouri is participate in this process!

If you’ve got any questions about this survey, triennial review, or what you can do to help, shoot me an e-mail at charles@mowaterkeeper.org.