Comprehensive Watershed Managment Issues
EPA Delays Release of Index of Watershed Indicators Until September
Background: EPA's Office of Water and its many public and
private partners are using joint information to characterize the
conditions of the 2,111 watersheds in the continental United States.
According to EPA, the purpose of the project is fourfold: (1)
characterize the condition and vulnerability to pollution of the
watersheds of the United States, (2) to empower citizens to learn
more about their watersheds and work to protect them, (3) provide
a basis for dialogue among water managers and, (4) to measure
progress towards a goal that all watersheds will be healthy and
productive places. 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: EPA has completed Phase I of the project; however,
delays in hard copy printing have caused EPA to schedule release
of the IWI until September 1997. AMSA will encourage members
to validate information in the IWI for their watersheds and forward
their concerns to the National Office. Also, AMSA members will
also be apprised on how additional information from their agencies
can be linked to EPA's site. 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: EPA has posted
a summary of comments received on the effluent trading document
on its Internet Web Site at http://www.epa.gov/owow/watershed/tradecom/tradecom.cfml.
Comments from 46 organizations, including AMSA can be viewed or
downloaded from the site. Though committed to finalizing the document,
EPA has cited a lack of staff resources and shifting priorities
as delaying its scheduled for release. EPA plans to solicit additional
stakeholder input through public meetings, potentially in Summer
1997. CONTACTS: Mark Hoeke, AMSA 202/ 833-9106, or Mahesh Podar,
EPA 202/260-5387.
TMDL Advisory Committee
Reviews List of Options
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: On June 11-13, EPA's TMDL Advisory Committee met in Milwaukee, Wisconsin, to review options being developed by its four workgroups to improve management and implementation of the TMDL program. Since the Committee's last meeting in February, the four workgroups; listing, criteria for approval, management and oversight, and science & tools, have been developing issue papers which summarize each phase of the TMDL process, highlight "hot button" issues, and propose options for program improvement. In its discussions, the Committee did not come to final consensus on any one issue; however, general or majority agreement was reached on a number of concepts, and several issues were delegated back to the workgroups for further discussion and refinement. Issues highlighted in the discussions included: whether to include "threatened" waters on 303(d) lists; whether EPA review and approval are required for TMDLs developed for waters impaired by nonpoint sources only; when waters should be removed from 303(d) lists; priorities for science & tool development which include monitoring, modeling, training, and decision-making under uncertainty; conceptual agreement on a 7-step hierarchial approach to TMDL approval; whether identification of implementation measures must be part of a TMDL; and whether prohibition on new or additional discharges should be imposed on water quality limited segments until TMDLs are developed and implemented. If you would like a copy of issue papers and meeting handouts, please contact Mark Hoeke, AMSA 202/833-9106. The next meeting of the Advisory Committee will be held September 3-5, 1997 in Portland, Oregon. CONTACT: Mark Hoeke, AMSA 202/833-9106 or Don Brady, EPA 202/260-5368.
AMSA Comments on EPA's Draft State Source Water Assessment and Protection Programs Guidance
Background: On April 4, EPA released draft guidance designed
to assist states in the development of new Source Water Assessment
Programs mandated by the Safe Drinking Water Act amendments of
1996. The assessments mark the first step of a long-term SDWA
program designed to protect sources of drinking water from pollution.
The April 8 draft guidance outlines time frames, processes, public
involvement requirements and the scope of what constitutes an
approvable state source water protection program, and provides
information on coordinating the program with other state and federal
pollution control efforts.
Status: AMSA submitted comments on the draft guidance on June 13, 1997. In its comments, AMSA supports the concept of source water protection and strongly encourages measures to link watershed management and source water protection efforts. AMSA suggests that a practical methodology for the addition of watershed planning to the source water assessment process and vice-versa must be developed. This methodology should discuss competing time frames, regulatory agency coordination, continual assessment, and cross-funding issues. AMSA also urges EPA to recognize the potentially significant implications of a susceptibility analysis in the source water assessment process, and ensure that the analysis is based on good science and good data. Other issues discussed in AMSA's comments include: recognition of state and local government, and water supplier cooperation in the assessment program; technical issues concerning delineation, such as the lack of "credit" for vertical travel times; source inventory information; community volunteer programs; time frames in the approval process; and technical/financial assistance in the petition process. AMSA concludes that in order to develop meaningful source water assessments, states will need more than two years to complete the assessments and that the guidance should recognize the significant need to include local governments and water purveyors in the development of a state's assessment program, and especially , in the completion of the source water assessments. EPA plans to finalize the guidance in August 1997, whereupon, states will have 18 months to submit their Source Water Assessment Program to EPA. CONTACT: Mark Hoeke, AMSA 202/833-9106.
American Heritage Rivers Initiative
Background: During this year's February 5th State of the
Union address, President Clinton announced an initiative to designate
American Heritage Rivers to help communities alongside them revitalize
their waterfronts, and clean up pollution. Each community supporting
a American Heritage River will be given resources to catalyze
their community's work on behalf of a restored, revitalized river.
The President has committed to designating 10 American Heritage
Rivers this year.
Status: EPA has extended the public comment period on
design of the American Heritage Rivers Initiative for 60 days.
On June 20, 1997, the President's Council of Environmental Quality
published a revised Federal Register notice to clarify
issues. Comments on the revised proposal are due August 20, 1997.
In the May 19 Federal Register, the President's Council
of Environmental Quality issued a proposal and request for comments
on the overall design of the American Heritage Rivers program.
Additional information can be obtained from the American Heritage
Rivers Initiative homepage at http://www.epa.gov/OWOW/heritage/rivers.cfml.
CONTACT: Karen Hobbs, Council of Environmental Quality 202/395-5750.