Oakland County, Michigan (November 9, 2007) - Finding the Right Tools to Fight Pollution

John P. McCulloch, Oakland County Drain Commissioner

Conference of Western Wayne Speech
City of Wayne, Michigan

There are two important points I want to make right at the onset so there is no mistaking my position. First, my office is dedicated to eliminating pollution in all of its myriad forms from any water body, be it a lake, pond, river, stream, or aquifer. If it pollutes the water, we’re against it.

That being said, the second point I want to emphasize is that the presence or absence of E. coli is not an appropriate means to measure the presence or absence of pollution in our waterways. It is the wrong measurement tool.

It’s important to talk about this now because yesterday the MDEQ released its latest Phase II NPDES storm water permit for public comment. That means if you are an urban community, the MDEQ is going to ask you to sign a permit that is likely to be violated every time it rains – even if no sewage is entering your storm water. You will be asked to seek and eliminate these sources of E coli even if they are the result of feral cats (as was documented in Ann Arbor).

The proposed watershed permit is too expensive, it is paperwork intensive, and it will not result in improved water quality. It may even drive communities to seek jurisdictional permits and undermine the cooperative efforts we have enjoyed over the past five years. That would be a mistake.

Recognizing that the MDEQ relies on E. coli measurement in its new permit requirements, I want to give you a little background.

E. coli bacteria come from both human sewage and a large number of sources in urban areas that represent an uncontrollable non-point source of fecal bacteria. The common test utilized by the MDEQ cannot distinguish between these sources. As a result, it is an inappropriate measurement for sewage detection precisely because it isn’t timely; it’s extremely variable and unreliable.

Storm water control will always be a difficult challenge because we have virtually no control over what others dump into our drainage systems.

Fortunately, we have options. I endorse the alternative being considered by the ARC, the Alliance of Rouge Communities. The ARC is proposing that a study be conducted to evaluate the reliability of fluorometric detection of optical brighteners for the presence of human fecal bacteria. That proposal holds promise because the fluorometric screening method could become an acceptable tool for detecting sewage in water.

I am urging all communities to write to the MDEQ during its formal public comment period from November 12 to December 12, and emphasize your support of the position already taken by municipalities in the Alliance of Rouge Communities.

The primary reason this alternative testing procedure looks so promising is because it is both sensitive and inexpensive. That contrasts sharply with using E. coli as a determinate. Water Quality professionals have long questioned the practical use of E coli as a test for sewage. Thus, we need a practical alternative that can guide us to sources of human sewage.

What is proposed is an alternative that combines targeted bacterial source tracking and fluorometric screening. The intent would not be to show whether pathogens are present – as is the case with E. coli measuring methods – but to show whether sewage is present. Fluorometric screening has the possibilities of being a timely and cost effective measurement tool and has already demonstrated a 100 percent success rate in estuaries and coastal environments where it has been tested.

The goal of the study proposed by the ARC would be to create a database correlating fluorometric detection of optical brighteners with the presence of human fecal bacteria. Armed with that kind of data, the fluorometric screening method could serve as an acceptable alternative to E. coli tests for detecting sewage in water.

My office remains committed to the protection of our region’s water resources. We are the headwaters of the Clinton, Flint, Huron, Rouge, and Shiawassee rivers and as such, our practices impact all of our downstream neighbors. We utilize a state-of-the-art field sampling program to identify and eliminate illicit storm water pollution. Currently, our water quality professionals frequently conduct E. coli sampling throughout Oakland County and find that, although no apparent dry weather illicit sanitary connections exist, background E. coli levels frequently exceed the proposed state water quality standard.

The E coli test has been a concern for decades but until now we have not been impacted by this technical challenge. The new storm water NPDES changes everything. Each urban community will be responsible for what comes out of their storm drains. We simply cannot rely on an unreliable test to determine our compliance.

In too many cases, our sampling is more a reflection on the lack of reliability of the tests, than the presence of sewage in the water. We can do better. If we adopt ARC’s proposal, we will.