Applied Ecosystem Services, LLC

The Environmental Issues Doctor

Water quality permit compliance monitoring data with concentration values exceeding statutory thresholds are assumed to result from permitted operations. Fines or penalties might be levied; remedial actions might be imposed. That permitted activities were responsible has not been demonstrated by the submitted data. This is particularly true when permitted activities are dispersed as mining, logging, and ranching are. Missing in permit compliance monitoring report evaluations is the context for those constituent values that exceeded thresholds.

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