Are Periodic Beach and Shellfish Bed Closures a Cost of Development?

In the past ten years, I have assessed beach and shellfish bed closures due to exceedances of indicator organism criteria in both fresh and salt water. In each case, the problem appears to be caused by factors/sources that are unlikely to be effectively controlled to eliminate the exceedances. In some cases, the proliferation of birds, such as Canada Geese and gulls, which have expanded their numbers due to their successful adaptation to our urban/suburban environment, is a key factor. In other cases, subsurface drainage to lower water tables in estuarine environments to allow new residential development leads to a first flush following rainfall that causes a short-term exceedance of bacterial indicator organisms. In still other situations, many older developed areas around fresh and salt waterbodies are served by storm drains that result in bacterial exceedances following storms. The nature of each of these sources, and perhaps the lack of public will to incur the substantial cost to reduce these exceedances, may mean that these problems are part of modern life.

A pragmatic strategy has emerged to allow us to “live in harmony” with these realities. State agencies are using local rain gauges to estimate when individual rainstorms are of sufficient magnitude to result in exceedances of indicator organism concentrations in surface water bodies. Once “exceedance rainfall” is observed, temporary closures are posted. After a few days, the state agency will sample the affected surface waters, and if indicator organism concentrations are below the water quality criterion (standard), then the area is re-opened for the designated uses.

Unfortunately, permanent solutions to this problem are likely to have highly uncertain effectiveness and may be quite costly. So, while we may not like the current approach, as it may suddenly disrupt plans for recreation, we may be unwilling to assume the cost of change. Ultimately, this may be another example where the goals of the Clean Water Act (to eliminate the discharge of pollutants into the nation’s waters, and to achieve water quality levels that are fishable and swimmable) are unlikely to be attained.