Ecological Management Action Plans

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EM-10 Reduction of Sewage Pollution

EVALUATION METHODS

EM-10 establishes a combination of educational programs, incentive programs, regulation development, inspection and enforcement mechanisms, and capital improvement programs with the end result being a reduction in the fecal coliform counts in BTES waterbodies. The usefulness of the various programs will be evident in 1) increased awareness of the sources of fecal coliforms and causes of impaired water bodies, 2) increased sewage pollution control, and 3) decreased fecal coliform counts.

Monitoring for this Action Plan includes assessing the timely implementation of the components of the Action Plan, and the eventual success of implementation (i.e., fecal coliform contaminants reduced). The first component is not conducive to monitoring in the traditional sense of data collection and analysis (e.g., water quality monitoring), but rather a tracking. The monitoring of implementation is designed to determine whether a better informed public (including agencies and local governments) resulted, and whether sewage pollution control increased within BTES. Eventual project success can be monitored with an analysis of data such as a reduction in fecal coliform contaminants in BTES or a reduction in the number of water bodies not meeting fecal coliform criteria. The success of action plans that target reduced sewage pollution, reduced agricultural pollution, and storm water management may all be manifested in similar improvements in water quality and indicators of ecosystem health. If all Action Plans are working in parallel and water quality improves, it will be difficult to determine the cause and effect. Since the scale of implementation will vary among Action Plans, the level of success in improved water quality will also vary. The probability is high that implementation of any single management scenario may have varying effects in different environments. It is also possible that no single indicator may indicate program success, but rather success will be seen in a combination of indicators. The end result of multiple actions to improve water quality, however, will be noticeable in indicators of basinwide ecosystem-level health (see CCMP-Part 4, "Monitoring Plan for Ecological Indicators"). Specific examples of project success are proposed below. They can be expanded or modified, should be reviewed periodically, and should be amended as appropriate.

A time line developed jointly by the funding agency and the implementor will provide the basis for the monitor to assess plan implementation. Because of the multiple components, interactions of components, and involvement of many agencies, a more detailed time line should be developed to track the progress of the development of the plan. Examples of time landmarks are:

Long-term success for implementation of sewage pollution controls is the reduction in number of fecal coliforms and the number of water bodies not meeting fecal coliform criteria. At the end of years 5 and 10, a statistical analysis should be conducted of the various fecal coliform criteria to determine whether the educational programs and sewage pollution controls have resulted in improved water quality. Examples of studies are:

Plan Implementation - The activities of various agencies outlined above in implementing the plan will be monitored for indicators such as:

Project Success - Any reductions in sewage pollution will be assessed by:

Plan Implementation - The monitor will contact the various agencies involved in the implementation to gather data (examples below) that will be incorporated into a monitoring report:

Project Success - The monitor will access appropriate data sets and conduct statistical analyses. Examples are:

Plan Implementation - There are no relevant sample designs or statistical analyses for the evaluation of plan implementation.

Project Success - Suitable baseline data may be available in LDEQ or LDHH databases. If not, a baseline status needs to be developed for studies of specific targeted areas (see above). Identification of any trends needs to be within the context of the variability of the system. Several statistical methods applicable to analysis of trends may be suitable. Data may be normalized and standard linear regression models can be used to detect trends once sufficient data points have been obtained (e.g., 15 years is considered the minimum for similar trend analyses conducted by Rabalais et al. 1995). If data cannot be normalized, nonparametric trend analysis techniques should be employed (e.g., modified Mann-Kendall tau tests and seasonal Kendall slope estimator tests; see Hirsch et al. 1982). Seasonal Kendall tau test is a nonparametric trend test that is appropriate for detecting monotonic trends in "time series" data, i.e., data routinely collected over time (or space). Differences can also be assessed geographically by an analysis of variance on transformed data for site differences. Where sites differ significantly, post-hoc comparisons are run to determine which sites differ from others. Power analysis will estimate the probability of detecting trends of a certain magnitude given a certain number of observations (see Appendix D in Regional Monitoring Program for The Galveston Bay Plan, Lane 1994). N.B. Identification of trends or correlations does not provide cause and effect relationships.

Because of the multiple plans throughout the 10-year period and the number of cooperating agencies, a 1.5 person-month per year is estimated for monitoring all the aspects of the Action Plan and the cooperative efforts of each agency (approximately one person-week per agency per year). Including salary, fringe, incidental costs, and indirect costs = $12,000 for each year (no inflation). Costs of statistical analyses are estimated at 4 person-months ($32,000 in each of years 5 and 10). A statistical consultant should also be used in year 1 to help design the statistical analysis to be employed at the end of years 5 and 10 and to determine the suitability of existing data and what baseline data are needed ($16,000 in year 1). Modifications in monitoring plan (see below) should result in modifications of cost.

Since BTMC is the proposed implementor for this Action Plan, an outside monitor not selected directly by BTMC is desirable. The combined work group of representatives of the cooperating agencies should agree to an outside monitor who will then be contracted by BTNEP. A monitor will prepare reports to be submitted to BTMC. Although individuals involved in the implementation of the Action Plan may prefer a team member to monitor the project, usually a Third Party offers the best option as the responsible individual for the monitoring. Independent reviewers should be free of vested interests, historic commitments, unrestrained by mission statements, and free from personnel or budgetary actions. The implementor and cooperating agencies will provide the project monitor with data products listed above for subsequent assessment of accuracy and incorporation into reports. The monitor should interact directly with each cooperating agency to determine their level of commitment and activities for the various reports. Success of the monitoring strategy depends on the commitment of participating agencies and individuals to make monitoring an integral part of the CCMP and to provide the Action Plan monitor with the data required to develop reports to BTMC. An additional outside monitor (i.e., statistician) should be contracted by the working group in years 1, 5 and 10. The results of the statistical analysis should be provided to the overall monitor of the Action Plan for presentation to the BTMC.

The monitor will prepare quarterly reports. Reports will be submitted not less than 15 days prior to a regularly scheduled meeting of the BTMC. The party responsible for the monitoring should be available to discuss the report at the meeting if requested to do so by the BTMC. Monitoring reports will also be provided to the agencies or institutions participating in implementation. Interim reports can be prepared by the monitor at any time to draw BTMC attention to significant problems, delays, etc. Statistical analysis of fecal coliform data will be conducted at the end of years 5 and 10.

The BTMC shall receive the quarterly reports. The BTMC shall discuss the monitoring document and take actions it feels appropriate with regard to the implementation of the Action Plan.

BTMC may at the end of any annual cycle change the periodicity or components of the monitoring reports if it feels the frequency or components of reports are inappropriate to keep abreast of the project. Changes in the independent reviewer can be made after any annual cycle, but only with the knowledge and participation of the work group of cooperating agencies, the independent reviewer, and BTMC.

Quality assurance/quality control in the usual sense of precision and reliability of data collection does not apply to most of the monitoring plan for this Action Plan, since the monitor is tracking the development and implementation of a series of programs and regulations. Certain features of quality assurance, however, can be applied to aspects of the monitoring plan:

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