Comprehensive Watershed Management Issues
EPA's National Watershed Assessment Project Presents Challenge
to AMSA
Background: EPA's Office of Water and its many public and
private partners are using joint information to characterize the
conditions of the 2,150 watersheds in the continental United States.
According to EPA, the purpose of the project is fourfold: (1)
characterize the condition of 2,150 watersheds in the U.S.; (2)
to stimulate and empower citizens who will now have access to
this aggregated information; (3) provide a baseline for a dialogue
among water managers; and, (4) to measure progress towards a goal
of healthy watersheds. EPA stresses that the project is a general
guide to watershed conditions, designed to open the door to further
dialogue and obtain more detailed information. EPA stresses that
NWAP is not a site-specific, detailed, high quality data source
on which to base individual activities such as establishing permit
limitations. Results of the assessment will be posted on EPA's
Internet "Surf Your Watershed" Web site (http://www.epa.gov/surf)
via maps and 2-page summary assessments for each watershed. Assessments
are expected to be ongoing as new data are identified or added.
Status: During a February 4th meeting of AMSA's Comprehensive
Watershed Management Committee, members discussed concerns regarding
preliminary data maps which indicate a significant amount of permit
noncompliance from point sources. Mike Cook, Director of EPA's
Office of Wastewater Management, indicated that EPA has investigated
the cause of these results, and cited that many excursions shown
on the maps may be due to residual chlorine exceedences, and may
also lie in the methodology used to incorporate effluent results
below detection. EPA plans to complete Phase I of the project
by April or May 1997. CONTACT: Mark Hoeke, AMSA (202) 833-9106
or Geoff Grubbs, EPA (202) 260-7040.
EPA's Draft Framework for Watershed Based Trading
Background: On June 10, 1996, EPA released a draft effluent
trading framework document detailing information on the types
of trading that can occur within a watershed, such as point-point
source, intra-plant, pretreatment, point-nonpoint source and nonpoint-nonpoint
source. It lays out the conditions necessary for allowable trading
to ensure that waters receive the same or better levels of protection
that would be attained without trading, stressing that "total
pollutant reduction must be the same or greater than what would
be achieved if no trade occurred." The document lists eight
principles of effluent trading that pollutant sources must follow
in order to meet water quality standards. For example, trades
must be developed within a total maximum daily load process or
other equivalent analytical and management framework, and affected
industry involvement and public participation are crucial components
to trading.
Status: AMSA submitted its comments on EPA's "Draft
Framework for Watershed-Based Trading." on September 6, 1996
(see September 1996, Regulatory Update). EPA offices
are internally discussing their concerns, as well as comments
received on the framework, including those from AMSA, and will
solicit additional stakeholder input through public meetings,
potentially in Spring 1997. Assistant Administrator for Water,
Bob Perciasepe, has released stated his commitment to finalize
the Framework in his recent National Water Program Agenda (distributed
to the membership via RA 97-5). CONTACTS: Mark Hoeke, AMSA
(202) 833-9106, or Mahesh Podar, EPA (202) 260-5387.
TMDL Committee Forms Workgroups to Address Issues
Background: Due to the number of lawsuits being filed by
environmental groups against EPA and states which have not met
TMDL development/implementation requirements under CWA Section
303(d), EPA continues to develop a broad strategy to reinvent
the TMDL process. Under CWA Section 303(d) states are required
to identify waters in which technology-based effluent limitations
are not sufficient to meet water quality-based standards, and
requires states to develop TMDLs for these waters which will ensure
that applicable water quality standards are met. EPA has formed
a federal advisory committee of stakeholder interests to develop
recommendations concerning needed changes to the agency's TMDL
program implementation strategy, as well as TMDL-related policies,
guidance, regulations and priorities. AMSA is represented on
the Committee and has formed an internal TMDL working group to
help identify priority issues among AMSA member agencies.
Status: The EPA TMDL advisory committee held its second
meeting on February 19-21 in Galveston, Texas. Participants discussed
the vision and mission of the committee as well as the status
of the listing, and science & tools workgroups. The listing
workgroup has held several conference calls and has been addressing
several questions such as: (1) should streams be subject to listing
if there is a failure to meet any component of the applicable
water quality standard (designated use, numeric, narrative, antidegradation,
wetlands criteria, flow standards, etc.)? (2) how should impairments
be identified, and what is the appropriate geographic scale?
(3) how should exceptions to the listing requirement be implemented
for situations where existing controls are seen as adequate to
assure attainment of water quality standards? (4) how should
"threatened waters" be defined and addressed, and (5)
how should EPA address inconsistency between state listing decisions,
while retaining flexibility for states facing different types
of problems. The science & tools workgroup has held several
conference calls and has focused on the "degree of rigor"
issue, or how and when to proceed with decision-making in light
of uncertainty and the degree of data quality necessary for decision-making.
The group has not reached any agreement thus far is this area,
but recognizes that it is important to assure a higher degree
of rigor when the consequences of the decision are greater. Several
approaches have been discussed which include: phase TMDLs, complex
TMDLs, simple TMDLs, and the possibility of taking uncertainty
into account in scheduling (targeting) TMDL development. The
next advisory committee meeting will be held in Milwaukee, Wisconsin,
June 11-13, 1997. CONTACT: Mark Hoeke, AMSA (202) 833-9106
or Don Brady, EPA (202) 260-5368
AMSA 1997 Summer Conference
The 1997 Summer Conference, "Point & Nonpoint Sources...Balancing
the Responsibility for Pollution Prevention," will be held
at the Madison Renaissance Hotel in Seattle, Washington, July
15-18. CONTACT: Mark Hoeke, AMSA (202) 833-9106.