An overall strategy of regulation should always include three tactics: (1) discharge limits at the end of the effluent pipe, based on a reasonable level of industrial technology; (2) water-quality-based limits, strict enough to eliminate sublethal effects beyond a mixing zone; and (3) periodic ecological surveys to check the effectiveness of the first two approaches. Sets of increasingly restrictive “Levels of Achievement” should be formulated to provide steps for management. The final level should represent an ultimate goal of eliminating deleterious discharges, i.e. the effluent-free mill.

Recent Australian regulations for kraft mills give a balanced blend of all three tactics. Federal requirements in U.S.A. also have the three tactics, with good water-quality limits for sublethal toxicity, but a blind spot for organochlorines. Canadian federal regulations continue to focus only on tactic no. 1, with little acknowledgment of the receiving ecosystems, although some provinces add that. Both Sweden and Finland regulate by tactic no. 1, but from a background of site-specific knowledge and needs; relatively uniform sites in the Baltic for Swedish mills, and a diversity of freshwater locations for Finnish ones.

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