Delaware Detox: Lessons From Our Past and Nonpoint Source Pollution in the Delaware River Basin Today
By MICHAEL CHENG, USA
Finalist, 2016 MIT INSPIRE Competition in the Arts, Humanities, and Social Sciences (History Category)
The cleanup of point source pollution in the Delaware River has long been hailed as one of the world’s top water quality success stories. The 330-mile river is home to one of the most vibrant populations in the world, both environmentally and economically.[i] The River’s waters and its cold tributary streams support a wild landscape rich in fish and wildlife, as well as the largest horseshoe crab population in the world.[ii] Additionally, the Delaware River is also the largest freshwater port in the world, sporting an active commercial fishery, busy shipping traffic, and heavy industry.[iii]
Nevertheless, the Delaware River was not always as clean as it is today. In years
past, the river was one of the nation’s most egregious embarrassments. In the early 20th century, the Delaware River was so filthy that ships passing through became discolored, waste clogged the engines of freighters in the harbor, and the drinking water that came from the river stank and tasted foul.[iv] “You can stand on Broad and Chestnut Streets and smell the river,” complained a local editor in 1944.[v] In addition, uncontrolled flooding caused frequent and devastating economic damage to homes and businesses throughout the city of Philadelphia.[vi]
Today, the Delaware River is under siege from the continued dumping of toxic pollutants in the river. In 2010, 6.7 million pounds of toxic chemicals were released into the Delaware River.[vii] Recently, the Delaware River was ranked the 5th most polluted river in the country.[viii] Unlike in the past, however, much of the pollution being taken in by the Delaware River today is nonpoint source pollution, particularly in the form of agricultural runoff. Nonpoint source pollution differs from the industrial point source pollution of the past in the difficulty of its proper detection and regulation, and it is particularly problematic as it cannot easily be traced back to any one particular source.[ix]
In order to successfully tackle nonpoint source pollution, policymakers will need to look to the Delaware River’s past, where the combination of public outcry and a new interstate organization dedicated to cleaning up the Delaware River would successfully regulate and control point source pollution, leading to the significantly cleaner river that Americans living in the Delaware River Basin region take for granted today. Examining the factors that led to the control of the Delaware River’s 20th century point source industrial pollution will help policymakers and concerned citizens develop a plan to successfully control the nonpoint source pollution that threatens the river today.
After the American Revolution, the Delaware River played a significant role in the industrial and economic development of the early United States. The region became one of the great iron and steel manufacturing centers of the nation due to its rich reserves of iron ore, forests, and limestone. The timber industry flourished and fed both paper mills and shipyards. Open-river shad fisheries provided residents one of their most important food sources and served as engines for economic development. Ships were built at the shipyards in Philadelphia, Chester, and Wilmington, and cables for bridges came from the area.[x] The Delaware Valley became the heart of America’s industrial revolution and emerged as one of the world’s greatest industrial areas.
By the late 1800s, major conflicts began to appear as increased dumping of waste from growing cities and industries overtaxed the river’s assimilative capability, reducing its ability to cleanse itself of pollutants.[xi] Factories and railroad yards cut off public access to the river, and the fishing industry nearly destroyed itself through overfishing.[xii] Additionally, low dissolved oxygen concentrations from pollution caused a sharp decline in migratory fish populations in the Delaware Estuary.[xiii] Millions of shad had once migrated up the Delaware River, and in earlier times, people caught them with nets, baskets, and anything else big enough to hold a fish.[xiv] However, overfishing and pollution soon changed the shad runs from an annual event to material for old timers’ tales.[xv]
In response to this pollution, the Pennsylvania government passed a 1905 statute requiring permits for sewage discharge. However, the state exempted industry completely, reflecting a willingness at the time to endure industrial pollution in return for the economic benefits of a well-developed industrial base.[xvi] Since most constituents at the time were either unaware of or uninterested in solving the challenges presented by industrial pollution, lack of political will on the behalf of their representatives meant that even minor controls on industrial water pollution would not be enacted until 1937 in Pennsylvania.[xvii]
A Call to Action
By the 1920s, it became clear that water pollution threatened the development of the Delaware Valley region. Sewage, carried in by pipes, was dumped en masse into the Schuylkill and Delaware Rivers, and in turn, the public water supply.[xviii] Frequent rainstorms caused the Philadelphia sewers to overflow and bypass sewage treatment plants, which poured millions of gallons of raw sewage and the runoff of city streets directly into the Delaware River.[xix] The river’s water was so dirty that it would turn the paint of ships brown as they sailed through it, and people were sickened by the smell of the river alone.[xx] Many parts of the Delaware Estuary were considered dead zones, devoid of the dissolved oxygen needed for the survival of fish and other aquatic life.
In 1936, the states of New York, New Jersey, Pennsylvania, and Delaware formed the Interstate Commission on the Delaware River Basin (INCODEL) to control water pollution, plan development of the river’s resources, and plan the conservation of the water supply.[xxi] At the time, the health of the Delaware River was so degraded that INCODEL called the water in the region “one of the most grossly polluted areas in the United States.”[xxii] To address this issue, INCODEL divided the length of the Delaware River into four water zones, establishing water quality standards, best practices, and regulations for each zone.[xxiii]
Unfortunately, INCODEL had little power of its own, and many of its actions were ineffectual at best. This ineffectiveness stemmed primarily from INCODEL’s structure as an advisory agency and its lack of any binding powers to regulate the Delaware River. As a result, each state could choose to either ignore or accept INCODEL’s suggestions, which made it virtually impossible for the states to reach consensus on pollution control policies, hampering exchange between the states.[xxiv] The presence of over eighty other federal, state, and local government agencies with differing agendas regarding river cleanup also hampered INCODEL’s efforts.[xxv] Consequently, most states’ individually enacted their own regulations regarding the river, which created a flurry of disjointed and inconsistent regulations along the Delaware River, hindering overall efforts to address industrial pollution.[xxvi] Still, the public, distracted by the booming economy and overseas engagement in World War II, was mostly complacent with INCODEL’s structure and river water quality. It would take a major flood in 1955 to energize the public enough to demand further action on the Delaware River from their state and local governments.
Formation of the Delaware River Basin Commission
In August 1955, two back-to-back hurricanes pounded the region, causing devastating flooding. The US Council on Environmental Quality wrote that “when the floodwaters had receded at last, 99 people were dead and $150 million in damages were sustained in the basin.”[xxvii] In the wake of the flood, a public outcry led to swift action. As a result, water quality issues were elevated to the national level, and Congress directed the Army Corps of Engineers and other federal agencies to create a comprehensive plan to develop and control the Delaware River’s resources.[xxviii] Within days, Governors Nelson A. Rockefeller of New York and David L. Lawrence of Pennsylvania began the process to create an agreement that would form a more powerful joint federal-state commission to develop and control the Delaware River’s resources, which would replace INCODEL.[xxix] The proposed commission would bring together the federal government and the state governments of Delaware, New Jersey, New York, and Pennsylvania to collectively and more effectively address issues in the Delaware River Basin.
In December 1960, the Army Corps of Engineers completed its plan to control and develop the Delaware River’s resources.[xxx] The plan advocated “a 50-year development program of 58 water control projects at a cost of $591 million to reduce flood damage, to augment stream flows and increase water supplies, to provide 41,000 acres of additional recreation waters, and to produce millions of kilowatt hours annually in conventional hydroelectric power.”[xxxi] However, many aspects of the plan were unable to be implemented because the plan failed to detail how its recommendations would be financed. Later on, many of the plan’s proposals would be enacted under the guidance of the newly-formed Delaware River Basin Commission.[xxxii]
Early Days of the Delaware River Basin Commission
On December 13, 1961, the Delaware River Basin Commission (DRBC) held its first meeting in Princeton, New Jersey.[xxxiii] The formation of the commission meant that for the first time the focus of all major water resource activities by federal, state, and local governments in the Delaware River Basin would be located beneath the roof of a single authority.[xxxiv] Before the commission’s formation, state governments had to take actions relating to the river individually, which prevented meaningful changes from being achieved in a reasonable time period, but the commission allowed states to confer together and streamline the formation of water policy along the river. Under a united front, the Delaware River Basin Commission would hope to solve problems regarding flood control, water supply, pollution, water-related recreation, fish and game protection, development of hydroelectric power and forest and soil conservation programs.[xxxv] Ultimately, the Delaware River Basin Commission’s formation would turn the tide in the Delaware River’s battle against industrial pollution.
The Delaware River Basin Commission wielded significantly more power than INCODEL, greatly aiding in accomplishing its mission. The DRBC’s formation consolidated the powers of 43 state agencies, 14 interstate agencies, and 19 federal agencies, which allowed a unified approach to water policy in the basin for the first time.[xxxvi] As part of its formation, the Delaware River Basin Commission was given powers to “acquire, operate and control projects and facilities for the storage and release of waters; for the regulation of flows and supplies of surface and ground waters of the basin; for the protection of public health, stream quality control, economic development, improvement of fisheries, recreation, dilution and abatement of pollution; [and] the prevention of undue salinity and other purposes.”[xxxvii] The commission was also granted the power to allocate interstate waters in accordance with the doctrine of equitable apportionment, which allowed it to set numerical groundwater withdrawal limits and pumping regulations in areas where water demands outstripped available supply.[xxxviii] Unlike INCODEL, the Delaware River Basin Commission’s decisions were made binding by a majority vote of the states involved, rather than through each state ratifying its own regulations individually, allowing the DRBC to take rapid action to respond to water quality issues.[xxxix]
In 1962, the DRBC established its Comprehensive Plan for the Delaware River Basin, which entailed over twenty different water control projects, from new reservoirs to dams, and most notably, mandated the development and implementation of water quality standards for the Delaware River and its tributaries.[xl] Within a year, the Commission began researching and developing policies to address water pollution. Under the Federal Pollution Control Act, the Commission used mathematical models and computers for the first time to forecast future conditions in the Basin and to determine the policies and costs that would be needed to obtain superior levels of water quality.[xli] In partnership with Rutgers University, the Delaware River Basin Commission initiated research that would determine the actual monetary relationship between water quality and resulting benefits for industry and the economy.[xlii]
A Water Quality Revolution
In 1965, as a wave of water pollution consciousness swept the nation, the federal government passed the Water Quality Control Act of 1965. The act required all state governments to adopt water quality standards for interstate waters for the first time in American history.[xliii] In itself, the requirement was the same for the Delaware River as for any other river, but what happened in the river basin went far beyond the minimum requirements. The basin community and the federal government had set up the DRBC, an agency aimed at tackling all regional water issues with input from partners such as citizens, environmental groups, and industry.[xliv] Furthermore, federal water quality authorities had just concluded their landmark Delaware Estuary Comprehensive Study, which used computerized techniques to determine the cause and effect of pollution in the river.[xlv] As such, unlike most other areas, the Delaware River Basin had both the administrative capability for the basin to undertake its own river cleanup and the results of a massive federal study of the conditions in the estuary.[xlvi]
In particular, the release of the results of the Delaware Estuary Comprehensive Study in July 1966 played a pivotal role in the Delaware River Basin Commission's development of anti-pollution standards. The findings of the federal estuary study revealed that the wastes being discharged into the river were eating up approximately one million pounds of the river’s dissolved oxygen per day.[xlvii] Combined with sludge and other demands, these discharges were found to tax the river’s assimilative capacity to such an extent that the Delaware River near Philadelphia was so deprived of oxygen that it was essentially a dead zone in Summer and Fall of every year.[xlviii] The study found that the effects of this were profound– pollution in the river drastically inhibited both aquatic life and recreation.[xlix] In addition, high levels of coliform bacteria and heavy acid discharges were also detected, which were responsible for many of the water quality issues in the basin.[l] The estuary study also offered five different policy suggestions that would help clean up the river, which would play an indisputable role in the development of the commission’s new water quality standards.[li] Combined with public pressure, the study made water quality the most important issue for the DRBC for years to come.
In 1967, the Delaware River Basin Commission adopted the first and most comprehensive water pollution control standards in the entire country.[lii] The new water quality standards targeted the dumping of harmful wastes into the Delaware River, which had led to dangerously low levels of dissolved oxygen that threatened the survival of fish and aquatic life in the river.[liii] The key features of the water pollution control standards included mandating disinfection of sewage, the issuing of wasteload allocation permits to approximately 90 waste dischargers, the adoption of significant penalties for noncompliance, and guidelines to help parties meet the standards.[liv] The water quality regulations not only targeted industry, but also governmental users. In particular, the City of Philadelphia, contributing nearly 50 percent of the entire river’s wasteload, would receive funds to install new sewage treatment plants to meet its abatement requirements.[lv]
In particular, the issuing of wasteload allocation permits which capped the amount of effluent companies could emit into the river is an excellent example of how the Delaware River Basin Commission’s unique structure made it especially effective at targeting water quality issues.[lvi] While the typical approach at the time was to give every industry being regulated the exact same standard to meet, this approach often favored larger companies and drove smaller companies out of business. Rather, the DRBC, using the information it had obtained from its earlier exchanges, gave different dischargers slightly different standards to meet depending on factors such as size and revenue.[lvii] With the mathematical models from prior studies and meetings from industry officials, the DRBC ensured that its standards were feasible for each waste discharger and balanced economic growth with environmental protection. Governor Charles L. Terry Jr. of Delaware concurred, calling the new water quality standards a program that would attract “the full support and aid of industry.”[lviii]
By 1981, the transformative effects of the Delaware River Basin Commission’s 1967 water quality standards had become easily apparent. By 1981, the pollution loadings to the tidal reaches of the river had been reduced by over 50 percent from their 1958 levels.[lix] Wasteload reductions amounted to well over 50 percent, in part due to new sewage treatment plants being installed by cities and towns that formerly lacked sewage treatment facilities.[lx] In particular, the City of Philadelphia reduced its daily discharge rate of organic pollutants from 150,000 pounds daily to 24,000 pounds, largely due to the DRBC’s 1967 water quality standards.[lxi] Fecal coliform discharge in the Delaware River Basin dropped by over 90 percent, from 4 million per 100mL to 300,000 per 100mL, which met DRBC’s water quality standards for the first time and rendered the river far safer and much more attractive for recreation.[lxii] Therefore, severe local pollution problems in many areas along the river had been eliminated.[lxiii]
Furthermore, the shad, an important indicator species of water quality and a popular game fish, had returned to the river in droves. Fred Lewis, the operator of the river’s commercial shad fishery, reported a catch of 6,392 shad, his fishery’s biggest catch since 1896.[lxiv] The verdict was in– the DRBC’s 1967 water quality standards had surpassed all expectations, and the Delaware River’s cleanup experience would prove to be a model for water resource experts worldwide.
However, the Delaware River Basin Commission’s work was far from complete. While the water quality of most of the Delaware River was now rated as “good to excellent,” the water quality of certain stretches of the river, particularly the Philadelphia stretch, was still only “poor to fair,” despite major improvements in water quality riverwide.[lxv] As the Delaware River Basin Commission’s water quality initiatives primarily targeted point source industrial pollution, nonpoint source pollution was left largely unaccounted for.
The Delaware River Today
Lacking close monitoring for several decades, the Delaware River today faces intensifying threats from nonpoint sources of pollution, such as logging and industrial development in the river’s headwaters, polluted runoff from farms and urban and suburban areas, aquifer depletion, and the looming prospect of hydraulic fracturing.[lxvi] Parts of the Delaware River are still not “fishable and swimmable” as mandated by the Clean Water Act.[lxvii] While it is clear to many scientists and policymakers that nonpoint source pollution is a problem, the public is unaware of the severity of the issue’.[lxviii]
A host of different organizations are involved in the protection of the Delaware River today. The Delaware River Basin Commission still plays a significant role in monitoring water quality on the Delaware River. However, due to declining state and federal funding and reduced public interest into the Delaware River’s water quality issues, the DRBC recently has been constrained to a more limited water management role.[lxix] This erosion of support for the DRBC has been evident in the gradual shift from attendance by the governors of states at commission meetings to attendance by lower-level political appointees and agency staff designates.[lxx] In recent years, the DRBC’s major role has been managing the droughts that have struck the Delaware Basin region, rather than taking on a strong stance on water quality issues as it did in the 1960s and 1970s.[lxxi]
Another organization that plays a major role in the Delaware River today is the Delaware Riverkeeper Network, an advocacy organization that takes a strong stance on regional and local issues that threaten water quality and the ecosystems of the Delaware River and its watershed.[lxxii] As a nonprofit organization of citizens and scientists alike, the Delaware Riverkeeper Network provides environmental advocacy, volunteer monitoring programs, stream restoration projects, and public education.[lxxiii] While the Delaware River Basin Commission is a partnership of states, the Delaware Riverkeeper Network is a partnership of citizens, who have more flexibility to advocate for specific issues than the DRBC alone.
A third organization in the Delaware River today is the United States Environmental Protection Agency (EPA), which is a federal government agency that aims to protect human health and the environment through the usage of environmental regulations, scientific research, and environmental advocacy.[lxxiv] The EPA has played a major role in solving some of the United States’ most challenging environmental issues, including air pollution, water pollution, and the biomagnification of DDT.[lxxv] Compared to the DRBC and the Delaware Riverkeeper Network, the EPA has been more politically constrained in its actions due to its status as a federal government agency.
However, while the DRBC, Delaware Riverkeeper Network, and EPA have all advocated for more stringent pollution control measures, a variety of obstacles have prevented them from being as effective at working on the task at hand as they could be. In regards to funding, support for the DRBC has declined in recent years. For instance, in 2014, Pennsylvania cut its contribution to the Delaware River Basin Commission by half, which has impaired the DRBC’s ability to take actions on water quality issues.[lxxvi] The Delaware Riverkeeper Network has been suffering from reduced citizen involvement in the environmental movement. In addition, increased political opposition against government spending has also made it more politically challenging for the EPA to make meaningful actions on the issue of water quality.
Actions Against Nonpoint Source Pollution
While most of the pollution control actions in the Delaware River Basin have
focused on point source pollution, there have been limited actions taken against nonpoint source pollution along the river. For example, in the upper west branch of the Delaware River in New York State, significant efforts have been taken to remediate nonpoint source pollution and protect the local water supply. Historically, the upper west branch experienced summertime eutrophic conditions due to high phosphorous loads (fertilizers) from nonpoint sources (farms), and in 1998, New York State listed this segment of the river on a list of impaired waters due to excess phosphorous levels.[lxxvii] Since that time, actions were taken by various agencies to reduce phosphorous levels on the river.
Initially, watershed partners, including environmental organizations and nonprofits, worked with government agencies to develop the Delaware County Action Plan, a comprehensive watershed management program that provided a framework for protecting water resources.[lxxviii] As part of the plan, the Watershed Agricultural Council, a local nonprofit, championed a voluntary incentive-based program where farmers implemented numerous best management practices, such as riparian buffers and collection of polluted runoff, to reduce agricultural runoff and improve water quality.[lxxix] As a result of the plan, dissolved phosphorous loads were reduced by 53 percent and particulate phosphorus loads by 36 percent.[lxxx] By 2004, the upper west branch of the Delaware River was removed from the list of impaired waters, underscoring how successful the plan was.[lxxxi]
More recently, in 2014, in tandem with other major watershed partners, the William Penn Foundation launched the Delaware River Watershed Initiative, a $35 million project aimed at protecting and restoring the Delaware River’s water quality and overall ecological health.[lxxxii] The initiative brings more than 50 leading nonprofits together to administer restoration projects and assess water quality impacts along the river.[lxxxiii] In particular, the nonprofits are focusing on reducing nonpoint source pollution, such as agricultural runoff and urban stormwater, in order to improve the water quality of the river.[lxxxiv]
In 2011, House representative John Carney introduced an act that would provide funding to support conservation projects in the river and help empower local organizations to restore the basin.[lxxxv] However, the bill died in committee due to a reluctance to fund it.[lxxxvi] Rep. Carney reintroduced the bill in 2013, where it also died in committee, and recently reintroduced the bill again in 2015 as the Delaware River Basin Conservation Act of 2015.[lxxxvii] However, the website Govtrack.us estimates that the bill has only about a 2 percent chance of being enacted, and as it did in 2011 and 2013, will likely die in committee again.[lxxxviii]
Tackling Nonpoint Source Pollution
While there have already been actions taken to address nonpoint source pollution on the Delaware River, such as the Delaware County Action Plan, the Delaware River Watershed Initiative, and the introduction of the Delaware River Basin Conservation Act of 2015, many other actions have floundered in the face of minimal public support for the actions, lack of funding, and political opposition. Given the significant obstacles that lie in the way of major solutions to nonpoint source pollution, it may be easy to simply give up on the issue and doom the river to an onslaught of agricultural runoff and toxic pollution. However, by looking back at the history of how point source pollution was cleaned up on the Delaware River, it becomes clear that a path to the cleanup of nonpoint source pollution is not only necessary, but also possible.
It took a hundred years for a strong coalition of government and nonprofit partners, widespread activism and public outcry, and a major disaster to emerge before significant action could be taken to address point source pollution along the Delaware River, but after those conditions were fulfilled, cleanup was swift. Within 20 years of the formation of the DRBC, the worst industrial pollution was eradicated, the long-endangered shad population had bounced back to normalcy, and certain sections of the river were once again fishable and swimmable.
These successes were only possible due to the presence of three major factors– public outcry, governmental will to address the public outcry, and a strong coalition of both government and nonprofit partners to take action. While the government showed a willingness to clean up water pollution as early as 1899, the public’s preference for economic development over environmental remediation hampered the government’s efforts to mitigate pollution. Even though INCODEL was formed as early as 1936, it had little power to address water pollution due to its disjointed political structure and contradictory water quality regulations across state lines. Eventually, public outcry after a devastating flood in 1955 would create the governmental will to fully address industrial pollution, and by 1961, the DRBC united both government and nonprofit partners to take collective action on point source pollution at last.
As the Delaware River’s history of point source pollution cleanup shows, it will take public outcry, governmental will to address the public outcry, and a strong coalition of both government and nonprofit partners to take action for nonpoint source pollution to be controlled along the river. However, not all of these factors currently exist, which is a key challenge in generating the impetus needed to clean up nonpoint source pollution along the river. According to a recent Gallup Poll, only 47 percent of the public is worried “a great deal” about pollution of lakes, rivers, and reservoirs, indicating lukewarm public will to address the issue.[lxxxix] In tandem with declining funding allocations for the Delaware River Basin Commission, the lack of significant public support presents a major problem for concerned citizens looking to clean up the river’s nonpoint source pollution.
Looking to the past success in cleaning up point source pollution can provide lessons for today, but it was far from straightforward with many false starts. The exemption of industry from the requirement of obtaining sewage discharge permits delayed river cleanup for over half a century. Had the states of New Jersey and Pennsylvania required industry to obtain sewage discharge permits in 1905 instead of waiting for the DRBC to mandate the exact same measure in 1967, the Delaware River likely would have avoided much of the industrial pollution that plagued the river for most of the twentieth century. The overemphasis on economic growth over environmental protection during the first half of the 20th century significantly delayed efforts to clean up the river and caused environmental problems to worsen until they could no longer be ignored. As history shows, placing short-term economic growth over long-term environmental protection will lead to a gradual worsening of an environmental issue until it becomes a serious emergency requiring billions of dollars in cleanup efforts.
The fragmentation of regulatory power across numerous well-intentioned but inefficient government agencies has resulted in a delay and lack of effective policy implementation significantly hampering efforts at cleaning up the Delaware River. As mentioned earlier, one of the primary reasons INCODEL was so ineffective was because it split regulatory power with dozens of other government agencies. With numerous government agencies and a host of nonprofit organizations working on the same issue, river cleanup was disjointed and delayed, and bureaucracy boomed. One of the primary reasons for the DRBC’s success was how it consolidated the powers of over 80 different local, state, and federal agencies. Therefore, policymakers looking to tackle nonpoint source pollution will need to ensure that they do not spread regulatory power too thinly.
Those who do not remember the past are doomed to repeat it. In light of the rapid decline of public fervor over environmental issues, it is especially important to look to past successes in the Delaware River Basin in order to address the insidious but damaging issue of nonpoint source pollution today. Governments and nonprofit organizations looking to clean up the nonpoint source pollution in the Delaware River Basin today will need to generate significant public interest concerning the issue before being able to take action, but once public interest is generated, action will be swift. Organizations such as the Delaware Riverkeeper should look towards social media to effectively spread their message and elevate public interest. The Delaware River Basin Commission should fight for greater funding to support environmental impact studies of nonpoint source pollution. Significant and sustained public engagement will be necessary to effectively address the issue of nonpoint source pollution in the Delaware River Basin.
The centuries it took for action to be taken on industrial pollution in the Delaware River serve as a blueprint for the factors needed to facilitate progress on environmental issues. While the government realized that pollution was a problem since the early 1900s, it was not until the middle of the century, after a devastating flood and numerous missed opportunities, that the public became concerned by the pollution that inundated the river. This case study in water policy underscores the importance of public interest in environmental issues before progress can be attained. Citizens and policymakers will need to keep in mind the environmental degradation of the past in order to clean up the nonpoint source pollution of the present. It is only through the careful study of past mistakes that progress on nonpoint source pollution can truly move forward.
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