Montana has five categories of “beneficial uses:” aquatic life, primary contact recreation like fishing and swimming, drinking water, industrial uses and agricultural uses. A given water body must meet the standards of whatever of those uses it is designated for. (File photo)

New DEQ document looks at water quality

DEQ measures metals, nutrients, pollutants in Madison watershed

ENNIS—Representatives from the Montana Department of Environmental Quality (DEQ) presented a new document to the public on Wednesday, September 27 that gives information on the health of several streams in the Madison River watershed.

The document, which reports the total maximum daily loads (TMDLs) of various pollutants, was written by the DEQ after certain streams presented high enough levels of certain elements to be labeled “impaired.”

The DEQ identified five particular streams in the Madison watershed that showed impaired levels of certain nutrients: Elk Creek, Hot Springs Creek, Moore Creek, O’Dell Spring Creek and South Meadow Creek. The Department writes individual TMDLs for each nutrient found to be in excess.

Impaired levels are those that exceed the state’s mandated water quality parameters. DEQ representative Christina Staten said Montana’s has five categories of “beneficial uses:” aquatic life, primary contact recreation like fishing and swimming, drinking water, industrial uses and agricultural uses. A given water body must meet the standards of whatever of those uses it is designated for.

Over the past six years, the DEQ as well as volunteers from the Madison Conservation District have collected data on a variety of pollutants in the watershed’s streams. Those pollutants are divided into three general categories: nutrients, metals and pathogens.



The nutrients in question included nitrogen and phosphorus. Staten noted that those two nutrients are beneficial at the right levels, but when present in excess can cause accelerated algae growth and algal blooms, which can kill fish and in certain cases, make humans and other animals sick.

The most common sources of both nitrogen and phosphorus in local waterways are ranching and agriculture, mining and septic drain field runoff. Natural sources of those nutrients also include local geology and wildlife excrement.

The document presented on Wednesday included TMDLs on nitrogen levels in all five of the creeks observed, as well as phosphorus reports for Elk, Hot Springs, South Meadow and Moore Creeks. 

The total maximum daily load for a given nutrient is defined by the DEQ as the maximum amount of that nutrient that a stream can hold and still meet statewide water quality standards. The levels reported in the TMDL documents included all the cumulative levels of nitrogen and phosphorus, including both natural and human-caused sources.

The metals the DEQ tested for covered a full spectrum, including aluminum, arsenic, cadmium, copper, iron, lead, selenium, silver and zinc. Elk Creek, South Meadow Creek and Hot Springs Creek all exceeded their recommended standards for at least one of those metals.

The dangers posed by excess metal content in waterways are well known, but Staten pointed specifically to the fact that those dangers include harm to both human and wildlife health, especially in instances where fish from those streams are caught and eaten by humans.

Metals bio-concentrate within the bodies of fish, so their levels can increase exponentially by the time they are eaten by something—or someone—else. There are no fish consumption concerns on the Madison watershed, says Staten, and one goal of the TMDL is to make sure it stays that way.

The most frequent culprit of elevated metal levels is mining, particularly abandoned mines, which can leach chemicals, tailings or runoff into nearby streams. Staten noted that there are more than 185 abandoned mines in the Madison Watershed.

There is only one item in the “pathogens” category that the DEQ tests for, and that is E. coli, which acts as an indicator for the presence of other pathogens. Only one of the streams included in the TMDL document included elevated E. coli readings, and that was Moore Creek. E. coli usually enters waterways via wildlife and livestock excrement. 



The DEQ’s document also provides suggestions for how to mitigate the elevated levels of nutrients, metals and pathogens present in various streams.

For nutrients like phosphorus and nitrogen, ranchers can change their grazing management practices to prevent overgrazing and soil erosion and can limit the points at which their livestock can reach a given stream. This helps to protect banks and keep pollutants from leaching out of eroding land into waterways.

The public can also help out with erosion control projects on particular streams and limiting high-concentration runoff, which comes from agriculture and septic systems.

For metals, Staten noted that the primary solution is addressing the primary problem of those abandoned mines. Mine reclamation projects that help to clean up old sites help to eliminate contamination at the source, and often projects like those can be funded through a variety of entities.

In the pathogen category, the primary source of contamination is excrement of any kind: residential septic tanks, livestock, pets and wildlife. Ensuring septic tanks are properly maintained and sealed, properly disposing of pet waste and effective ranch management all may seem trivial on an individual basis but can make a huge difference to stream health when communities take a collective effort.


Passing the baton

The TMDL document is a required step for the DEQ under the federal Clean Water Act of 1972. The problem is, its power largely ends in the information-gathering stage.

“The TMDL gives the specific parameters for a given watershed,” said DEQ representative Lou Volpe at Wednesday’s meeting. “It informs and gives incentives but can’t enforce. It doesn’t have any regulatory teeth.”

That is largely true: the state DEQ is tasked with protecting the air, water and land resources of Montana, but the TMDL process is voluntary and non-regulatory, so if landowners and residents of the watershed didn’t want to address the problems present, DEQ would not be able to compel them. 

The only entities compelled to cooperate with TMDL regulations are parties with designated discharge permits, which are limited to certain amounts and concentrations of discharge and can’t have an excessive negative impact on a waterway.

Staten noted, however, that the Madison Valley is unique in that it already has active and engaged community members who care about their local waterways. 

Groups like the Madison Conservation District and the Stream Team volunteers who have conducted water quality testing since 2010; tourism and fishing agencies who want to keep the Madison the worldwide fishing draw it is; and agricultural landowners who want to do their part to minimize their impact on local ecosystems can all play important roles in improving the health of impaired streams.

And there are avenues to bring all those stakeholders together now that the TMDL document is complete.

Once its public comment period has ended on October 19 and relevant edits have been made, it will be submitted for approval by the Environmental Protection Agency (EPA). Once that happens, the impaired streams can become eligible for EPA funding to pursue remediation efforts. 

The information from the TMDLs will also go toward another document that has been in the works for the better part of a decade.

Ethan Kunard, water projects manager for the Madison Conservation District (MCD), said the Madison Watershed Plan will incorporate the conclusions from the TMDL. From there, local projects that cooperate with landowners, community members, sustainability organizations and water quality standards can begin. 

“This TMDL is important because we’re in what’s called an enclosed basin,” Kunard said Wednesday. “We don’t have any more water to work with besides what’s here.”

Over the past several years, the MCD has conducted meetings and surveys with community members to identify what they viewed as priority issues when it came to conservation. The TMDL data can be incorporated into local efforts to solve the problems the community cares about the most like wells, grazing, population growth, climate change and fisheries.

“We have the opportunity to look at these TMDLs and launch our conservation efforts, tying all those community values and concerns together,” said Kunard.


The TMDL can be found in its entirety online at or in disc format at the Madison Valley Public Library. Public comment will be accepted online or by mail through 5 p.m. on October 19. Staten is the public contact for the Madison watershed TMDL project; she can be reached at

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65 N. MT Hwy 287
Ennis, MT 59729

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