They contain no measurable nor clearly stated standards for determining when surface water must be filtered. No allowance or recognition is made for biogeochemical purification by the landscape. The rules only allow filtration by an installation manufactured by the water filtration industry, with concomitant large inputs of energy and chemicals from outside the watershed. No equivalent investment and no stature has been given to natural systems. The Croton is nearly twenty-five percent publicly owned, and the watershed is largely managed forest, but no distinction is made between a watershed which is ninety percent paved and one that is ninety percent greenspace.
Control is defined only by ownership.
The rules thus equate private ownership with water quality degradation. Ownership, however, does not determine water quality. Biogeochemical activity and water-holding capacity do, regardless of ownership. In other words, it's not who owns the land, but how it is managed. The EPA has left in its rules no role for stewardship.