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Watershed-Based Permitting May Help Cities
Meet Standards, Treatment Officials Told
BOSTON--Municipalities facing stricter clean water standards and decreasing
resources to meet those standards should consider watershed-based permitting as
a way to get more environmental return for their investment, wastewater
treatment officials were told July 17.
Watershed permitting is one way to bridge Clean Water Act programs affecting
dischargers within a given geographical boundary, Lisa Bacon, a principal
technologist with CH2M Hill in Herndon, Va., said. She spoke at the summer
conference of the Association of Metropolitan Sewerage Agencies.
"This is not just about synchronizing permits in the same basin," she said.
Rather, the concept involves creating a single National Pollutant Discharge
Elimination System permit to address multiple clean water issues, such as
combined sewer overflows, stormwater, and discharges affecting a basin.
The Environmental Protection Agency has been advocating the idea and released a
policy statement on watershed-based permitting in January.
"Watershed-based permitting can encompass a variety of activities ranging from
synchronizing permits within a basin to developing water-quality based effluent
limits using a multiple discharger modeling analysis," a Jan. 7 memo to the
agency's regions from G. Tracy Mehan, EPA assistant administrator for water,
said. "The type of permitting activity will vary from watershed-to-watershed,
depending on the unique circumstances in the watershed and the sources impacting
watershed conditions."
Bacon discussed the four types of watershed permits described by EPA in the
memo:
A general permit for common sources or categories of sources, such as publicly
owned treatment works or concentrated animal feeding operations, within a
watershed;
A general permit for collective sources that would be similar to the
multi-sector general permit already available for stormwater dischargers;
An individual permit that covers multiple point source dischargers within a
watershed; and
An integrated municipal NPDES permit that bundles the permit requirements for
all municipal discharge points under one permit.
Watershed permitting has several advantages, Bacon said, including the fact that
it allows monitoring programs to be consolidated, which produces fewer gaps in
data.
"You can really focus on what's going on and where you can get the biggest bang
for the buck on monitoring," she said.
Municipalities would also be able to combine limits set in their separate
permits into one permit, which would allow for trading. For example, a POTW in
one town on a river may have a slightly stricter limit for a pollutant than
another POTW upstream. Instead of separate permits for the two facilities, one
watershed permit could be issued establishing one limit for the pollutant, and
the two treatment plants could work out a way to meet that limit, she said.
"It provides the mechanism for a cooperative approach among multiple facilities
to achieve shared goals," Bacon said.
While watershed permitting may be more resource-intensive up front in terms of
requiring more collaboration and cooperation, Bacon said she thinks that it
means a "better payoff in the end."