United States
Environmental Protection
Agency
Office Of Water
(4203)
EPA 833-R-96-001
March 1994
xvEPA
Moving The NPDES Program To
A Watershed Approach
-------
WATERSHED
PROTECTION
NPOI
WATERSHED
STRATEGY
MOVING THE NPDES PROGRAM TO
A WATERSHED APPROACH
October 1994
U. S. Environmental Protection Agency
Office of Wastewater Management
Permits Division
401 M Street S.W.
Washington DC 20460
-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY [[[ i
1.0 Introduction [[[ 1
1.1 Background [[[ 1
1.2 Purpose and Methodology [[[ 1
1.3 Organization of this Report ........................................ _ ............................... 2
2.0 Regional Internal Strategies [[[ 3
2.1 Status [[[ 3
2.2 Approaches [[[ 3
2.3 Organizational Change [[[ 4
3.0 State Assessments and Regional Action Plans [[[ 4
3.1 Status [[[ 4
3.2 Approaches [[[ 5
3.3 Regional Observations [[[ 6
4.0 NPDES Watershed Strategy Components [[[ 6
4.1 Statewide Coordination [[[ 6
4.3 Monitoring and Assessment [[[ 7
4.4 Programmatic Measures and Environmental Indicators ................................ 8
4.5 Public Participation [[[ 8
-------
EXECUTIVE SUMMARY
The Watershed Protection Approach represents the Environmental Protection Agency's
(EPA's) renewed emphasis on understanding and addressing all surface water, ground water, and
habitat stressors within a geographically defined area, instead of viewing individual pollutant
sources in isolation. On March 21, 1994, EPA's Assistant Administrator for Water signed the
National Pollutant Discharge Elimination System (NPDES) Watershed Strategy. The purpose of
the Strategy is to integrate the NPDES Program into the broader Watershed Protection Approach
and support development of Statewide basin management approaches (BMAs)1. Basin
management is a Statewide approach designed to meet the objectives of the broader Watershed
Protection Approach. The Strategy identifies key action items for the'NPDES Program and
emphasizes critical areas in which the NPDES Program must coordinate its point source control
activities with the efforts of other water programs.
The Assistant Administrator for Water requested three products from EPA Regions in
the NPDES Watershed Strategy transmittal memorandum:
• State-by-State Assessments and Regional Action Plans - An assessment of
watershed protection activities and needs in each State and, in light of that
assessment, plans that identify how the Region will support and facilitate each
State's movement toward the Watershed Protection Approach;
• State/EPA Workplan Agreements - Specific activities within State/EPA
workplans for fiscal year 1995 that promote the central components of watershed
protection;
• Internal Coordination - Integrated Regional strategies that describe the Regional
decision making processes, oversight role, and internal coordination efforts of the
various water programs necessary to ensure support for the Watershed Protection
Approach.
During the months of June and July 1994, representatives from the Office Wastewater
Management (OWM), Permits Division, visited each EPA Region to discuss Regional progress in
implementing the NPDES Watershed Strategy. This report represents a synthesis of the
individual Regional reports. In particular, it discusses approaches to developing and progress
toward completing Regional Internal Strategies, and State Assessments and Regional Action
Plans; activities related to the NPDES Watershed Strategy components; Regional issues and
needs concerning the Watershed Protection Approach; and expected benefits from implementing
the Watershed Protection Approach.
!For the purposes of this document, the terms Statewide basin management approach (BMA) and Statewide
watershed protection approach are intended to refer to the same concept; they are comprehensive Statewide
approaches to managing water resources on a geographic basis.
-------
The findings of the Regional reviews suggest that Regions are making progress in
implementing the Strategy since it was completed in March 1994. Nine of the ten Regions
projected that they would submit their Internal Strategies and completed State Assessments and
Regional Action Plans for 39 States and Puerto Rico in September 1994. Assessments and
Regional Action Plans for 12 additional States and the District of Columbia are expected to be
completed in fiscal year 199S. Most Regional offices have established some variation of an
internal workgroup to serve as a focus for Regional watershed protection efforts. These
workgroups tend to have multi-program representation from both the Water Management
Division and Environmental Services Division.
Regions have also taken steps to implement the six NPDES Watershed Strategy
components: (1) statewide coordination; (2) NPDES permits; (3) monitoring and assessment; (4)
programmatic measures and environmental indicators; (5) public participation; and
(6) enforcement The report discusses some of the Regional efforts related to these components.
During the mid-year visits each Region was asked to identify issues they felt may impede
and activities they felt would assist the implementation of the Watershed Protection Approach.
The combined list of Regional issues and needs reflect common themes such as the need for
coordinated leadership within the Office of Water (OW) for implementing the Watershed
Protection Approach, and flexibility in implementing watershed protection efforts.
During the Regional visits, OWM asked the Regions to identify examples of
environmental progress which result from the application of a watershed strategy to address
existing issues or problems. The Regions also identified areas where they expect that a broad-
scale watershed strategy, such as a Statewide basin management approach, will prove beneficial
to the environment and to Regional and State agencies. Examples from both of these areas are
compiled in a section of this report.
ii
-------
1.0 Introduction
This section describes the Watershed Protection Approach and the NPDES Watershed
Strategy, outlines the purpose of this report, and provides a description of its-organization.
1.1 Background
The Watershed Protection Approach is an Office of Water {OW) wide initiative which
promotes integrated solutions to address surface water, ground water, and habitat concerns on a
watershed basis. The Watershed Protection Approach isnot a new program; rather, it is a
decision making process that reflects a common strategy for information collection and analysis
and a common understanding of the roles, priorities, and responsibilities of all stakeholders
within a watershed.
On March 21, 1994, EPA's Assistant Administrator for Water signed the NPDES
Watershed Strategy. The purposes of the Strategy are to demonstrate EPA's commitment and
approach for integrating the NPDES program into the broader Watershed Protection Approach
and to support the development of Statewide basin management approaches. The Strategy
identifies key action items for the NPDES Program and emphasizes critical areas in which the
NPDES Program must integrate its point source control activities with the efforts of other water
programs.
As first steps toward implementing the NPDES Watershed Strategy, the Assistant
Administrator requested that EPA Regions complete three products by September 1, 1994.
These three products are:
• State-by-State Assessments and Regional Action Plans - An assessment of
watershed protection activities and needs in each State and, in light of that
assessment, plans that identify how the Region will support and facilitate each
State's movement toward the-Watershed Protection Approach;
• State/EPA Workplan Agreements - Specific activities within State/EPA
workplans for fiscal year 199S that promote the central components of watershed
protection;
• Internal Coordination - Integrated Regional strategies that describe the Regional
decision making processes, oversight role, and internal coordination efforts of the
various water programs necessary to ensure support for the Watershed Protection
Approach.
1 2 Purpose and Methodology
The purpose of this report is to summarize the status of implementation of the NPDES
Watershed Strategy. More specifically, the report:
Highlights EPA Regions' efforts to implement the*NPDES Watershed Strategy;
-------
• Describes issues of concern and needs raised by Regions with regard to the
Watershed Protection Approach and the NPDES Watershed Strategy;
Provides information to EPA Regions about the various approaches being used by
their counterparts to conduct the State Assessments, Regional Action Plans, and
Internal Strategies:
Provides feedback to EPA Headquarters on desired support for implementing the
Watershed Protection Approach; and
• Offers Regional perspectives on the successes that may result from applying the
Watershed Protection Approach to protect and restore water resources.
During the months of June and July 1994, representatives from the Office of Wastewater
Management (OWM), Permits Division, visited each EPA Region to discuss Regional progress in
implementing the NPDES Watershed Strategy. These visits were different from those of
previous "mid-years" or "Regional reviews" years in four ways. First, the discussions
concentrated on planning and future events rather than past performance. Second, the main
topics of discussion centered on the NPDES Watershed Strategy and the Watershed Protection
Approach. Third* the Headquarters representatives used common questions and Regional report
format to maintain consistency in information gathering across Regions. Finally, this year's
Regional visits addressed not only on the status of Regional efforts in implementing the NPDES
Watershed Strategy, but also afforded the Regions the opportunity to express their needs and
concerns relative to the Strategy and the Watershed Protection Approach. During each visit,
Headquarters representatives prepared a substantially complete draft of the Regional report and
discussed it with each Region. Any Regional comments were incorporated and a final draft
report was prepared for each Region. This report represents a synthesis of the individual
Regional reports.
13 Organization of this Report
The remainder of mis report is organized as follows:
• Regional Internal Strategies - Summarizes the status of the Regions' efforts to
establish Internal Strategies to ensure support for the Watershed Protection
Approach or its approach to developing one. It also discusses the various
procedural and organizational approaches used by the Regions.
• State Assessments and Regional Action Plans - Summarizes the status of
completion of the State Assessments and Regional Action Plans and describes tht
range of approaches taken by the Regions to develop the assessments and plan*.
• NPDES Watershed Strategy Components - Discusses actions being taken by
the Regions to address Strategy components such as statewide coordination,
-------
NPDES permits, programmatic measures and environmental indicators, monitoring
and assessment, public participation, and enforcement
bines and Needs - summarizes issues raised by Regions with regard to
implementing the NPDES Watershed Strategy and the Watershed Protection.
Approach; needs indicated by Regions as necessary to successfully implement the
Watershed Protection Approach; and feedback on potential OWM activities
intended to support the Strategy.
Expected Benefits • identifies examples of success resulting from application of a
watershed strategy to existing issues or problems.
2.0 Regional Internal Strategies
The Assistant Administrator for Water requested that each Region submit to the Office of
Wastewater Management (OWM) an Internal Strategy dealing with how it plans to make
decisions, provide oversight, and coordinate its water management programs to ensure support.
for the Watershed Protection Approach. A portion of the Regional visits focused on the
progress made and approaches taken to develop these strategies.
2.1 Status
Nine Regions projected that they would submit an Internal Strategy in September 1994. The
remaining Region expects to complete its strategy in the first quarter of fiscal year 1995. This
delay is due to extensive State involvement in the strategy development process
22 Approaches
Most Regions have taken two basic approaches in developing an Internal Strategy: 1) internal
workgroup; and 2) State coordination- All Regions are developing an Internal Strategy
document to coordinate implementation of Regional watershed activities and to support States'
efforts to implement the Watershed Protection Approach. Most Regions have involved the
following programs in the development of their Internal Strategy: NPDES; Nonpoint Source;
Wetlands; Ground Water, Drinking Water, Enforcement; Water Quality; geographically targeted
programs, such as the National Estuary Program and the Great Lakes Initiative; State Revolving
Fund; and Geographic Information Systems (GIS). In most cases, either the Water Quality
Branch or the Wetlands and Watershed Branch has the overall Regional lead for watershed
implementation. In addition, all but one Region has identified an NPDES watershed lead to serve
as poi nt of contact for NPDES involvement in watershed implementation. The NPDES leads are
often the Permits Branch Chief or the Permits Section Chief. Attachment A provides a list of
Regional and State Watershed Point of Contacts.
Internal Workgroup: Most Regions have established some variation of an internal workgroup to
serve as a focus for Regional Watershed Protection efforts and to develop their Internal Strategy.
-------
These workgroups tend to be well represented from across the Water Management Division and
from the water-related programs in the Environmental Services Division.
State Coordination: Many Regions have held State meetings to discuss and to exchange ideas on
how to implement the Watershed Protection Approach. Some Regions have taken a more active
approach to involving their States in the decision making process. Region 5 has established a
State workgroup to comment on and approve the Region's Internal Strategy. Region 5 also has a
State Quality Action Team which, among its other responsibilities, serves as a means for
developing watershed implementation actions within the Region. Region I has created State
Coordinator Groups, which include representatives from most of the Region's water programs, to
support each State. These groups are responsible for relaying information about the Watershed
Protection Approach to the State on a program-by-program level.
rfinnfll Chane
As a result of the Internal Strategy development process, several Regions have made
organizational changes to help improve internal coordination. Region 1 is conducting a pilot
reorganization of one of its NPDES program sections to better support me State of
Massachusetts'* implementation of the Watershed Protection Approach. The former MA
NPDES Section is now the MA Watershed Section and includes both water quality and water
modeling staff. As part of this organizational change, Region 1 has funded a position for a
"Resource Protection Specialist" responsible for identifying critical resources in the Region and
targeting regional efforts to address those priorities. Region 10 created a "Watershed
Coordinator" position to oversee the NPDES program's implementation of the Watershed
Protection Approach. The Coordinator is specifically responsible for assisting States in the
development of a Statewide basb management approach.
3.0 State Assessments and Regional Action Plans
State Assessments are intended to examine a State's current watershed protection activities and
needs. Regional Action Plans then identify how the Region will support and facilitate
implementation of the Watershed Protection Approach in each State based on the results of the
State Assessment A portion of the discussion during OWM*s Regional visits centered on
progress made and approaches taken to develop the State Assessments and Regional Action
Plans.
3.1 Status
The Regions projected that they would submit State Assessments and Regional Action Plans for
39 of the States and Puerto Rico in September 1994 and for 12 additional States and the District
of Columbia in fiscal year 1995. There are currently no plans to develop a State Assessment or
Regional Action Plan for the remaining territories.
Some Regions have developed well planned strategies for completing State Assessments and
Regional Action Plans, but believed that submissions for one or more States should be delayed
until after September 1994 for a number of reasons, including: insufficient time to complete
-------
thorough reviews of all States; inadequate travel funds in 1994 for State visits that would form
the basis of the assessment; and present difficulties entering a dialogue with the State concerning
watershed protection. Attachment B lists the scheduled completion dates for each State
Assessment and Regional Action Han and highlights progress in each State at the time of the
Regional visit
3.2 Approaches
Regions have taken at least one of four basic approaches to conducting State Assessments and
developing Regional Action Plans: 1) internal teams; 2) State meetings; 3) State questionnaires;
and 4) facilitated workshops. Some Regions selected different approaches for different States.
Most Regions made use of the May 1994 "Regional Guidance for Development of State-by-State
Assessments and Action Plans" provided by OWM to complete the State Assessments and
Regional Action Plans, and several Regions added contributions from other programs to the
material included in the guidance.
Internal Teams: By far the most common approach taken is convening internal Regional teams to
complete both the State Assessments and Regional Action Plans. Five Regions have formed
internal teams for one or more of their States. In general, these teams cut across program lines
and include staff and management from the Environmental Services Division in addition to several
water programs. Region 10 hdd a workshop to develop the State Assessment and Regional
Action Plan for Idaho. Sixteen staff from the Wastewater Management and Enforcement Branch,
Surface Water Branch, Environmental Sciences Division, and the Ground Water/Drinking Water
program participated in this workshop. The State Assessment was largely completed by the end
of the first day; a conference call on the second day with representatives from the Idaho
Department of Environmental Quality was used to fill information gaps.
State Meetings; Three Regions held or are planning to hold meetings with one or more of their
States. The format for these meetings ranges from requesting information to supplement existing
data, such as during a Region 8 State program directors' meeting, to formal assessments, such as
those planned by Region 5 during the fiscal year 199S annual State performance evaluations.
State Questionnaires: Two Regions are developing their State Assessments and Regional Action
Plans based on the results of detailed questionnaires sent to each of their States. The
questionnaires are modeled after the OWM guidance on State Assessments and Regional Action
Plans. Regional teams follow-up with States either to get additional information or to allow the
State to review the draft assessments and action plans.
Facilitated Workshop: Two Regions are using outside facilitators to help them develop State
Assessments or Regional Action Plans or both. The facilitator, provided through OWM contract
funding, helps Regional teams walk through the process of developing a State Assessment and
Action Plan based on the OWM guidance.
-------
3.3 Regional Qbservatiqns
Regioas generally believe the Stale Assessments and Regional Action Plans are helpful tools for
evaluating Stated progress in developing watershed approaches and for guiding Regional work
plans for Fiscal Year 1995. Some RTgian*commented that developing these products is both
time consuming and labor intensive, but they are finding the process beneficial.
The Assistant Administrator for Water asked Regions to include specific watershed protection
activities in fiscal year 1995 Stale/EPA work plans. Most Regions indicated that they would be
better able to influence* the fiscal year 1996 planning process due to the scheduled completion
date for the State Assessments and Regional Action Plans (late fiscal year 1994).
4.0 NPDES Watershed Strategy Components
The NPDES Watershed Strategy identified six components that should be addressed to fulfill the
purpose and objectives of the Strategy: (1) statewide coordination; (2) NPDES permits;
(3) monitoring and assessment; (4) programmatic measures and environmental indicators; (5)
public participation; and (6) enforcement Associated with each of these six components are
actions that EPA Regions may take to support the purpose and objectives of the NPDES
Watershed Strategy. OWM assumed that most Regions would undertake such activities after
developing State-by-State assessments and action plan*. During fee Regional visits, however,
OWM found that a number of Regions are already making progress in supporting the six Strategy
components.
4.1 Statewide Coordination
A number of Regions are supporting their States in developing or implementing Statewide basin
management approaches that allow them to integrate management activities (monitoring,
assessment, TMDL development, permitting, nonpoint source controls, ground water
protection) aimed at aquatic ecosystem protection within the boundaries of a given basin. These
approaches are tailored to the unique circumstances of each State, and not all programs or
agencies are participating in each State. Support from the Regions for developing, expanding, and
implementing Statewide basin management approaches is critical to the success of the NPDES
Watershed Strategy. Region 4 is drafting a Statewide Watershed Protection Approach that could
be a basis for implementation by Florida Department of Environmental Protection of the NPDES
Strategy upon authorization of the Florida NPDES program. Additionally, Region 4 is actively
supporting Georgia in their efforts to develop a Statewide basin management framework
document.
Regions also are directing I04(bX3) money to projects that promote Statewide coordination and
development of Statewide basin management approaches. Oklahoma received $100,000 to
establish an administrative process that will integrate and coordinate point and nonpoint sourc*
pollution control activities within a basin; develop a Statewide basin management framework
document; and conduct facilitated workshops that will promote acceptance of the Statewide
Watershed Protection Approach at all levels of government. Utah received $31,000 and Oregon
received $44,251 to develop a Statewide basin management framework document. Montana
-------
received $20,000 to develop educational materials and * training curriculum to Fidlititt Statcrridc
watershed planning at the local, State, and Federal levels.
42 NPDES Pennita
In most Regions ana at tr A Headquarters, the NPDES program is a relatively new stakeholdertn
the Watershed Protection Approach. The NPDES Watershed Strategy represents an attempt by
OWM to define the role that the NPDES program can play in developing an integrated,
geographically based approach, to water resource management la most lUgMB*, tfa« NPDES
program is now playing a role on a Regional watershed team. As Regions develop their internal
watershed strategies and assist their States in developing watershed approaches, the NPDES
program will be a key contributor. This is evidenced by examples such as the Watershed
Coordinator hired within the Region 10 NPDES program and by the pilot reorganization within
Region 1's Water Management Division to support MA's implementation of a Statewide BMA.
Regions have also begun to address specific NPDES permitting issues on a watershed basis. For
example, Region 6 successfully identified and issued "minor" NPDES permits to several shrimp
processors that were contributing to a water quality problem on Bayou Grand Calliou, Louisiana.
In setting permitting priorities, the Region focused on the watershed and the known water quality
problems rather than the distinction between "major" and "minor" permittees. Region 9 is
working with the State of Arizona to demoflsTratt On uflEty orNPDES permitting on a
watershed basis. The Region and State will work with local stakeholders to sequence the
standards and permits process with other water quality management efforts.
4.3 Monitoring and Assessment
To meet the objectives of the NPDES Watershed Strategy, States should develop a Statewide
monitoring strategy that assures the most effective targeting of limited monitoring resources and
coordinates collection and analysis of NPDES, nonpoint source, and other watershed data.
Additionally, the Strategy encourages ambient monitoring requirements in NPDES permits,
where appropriate, to support assessment or watershed conditions. Regions have not begun to
implement the Monitoring and Assessment component of the NPDES.Strategy. However, the
Regions are supporting their StataF who are implementing or developing watershed monitoring
and assessment programs. For example: 1) Illinois has a monitoring program which is based on
a basin management cycle and; 2) Arizona, with EPA grant assistance, is conducting the
monitoring, assessment, and planning activities in the Middle Gila Basin necessary to develop
and issue multiple NPDES permits in the targeted basin.
Several States received 104(bX3) funds for monitoring and assessment projects that support the
NPDES Watershed Strategy. California received $100,000 for a comprehensive watershed
project which includes water quality assessment, and monitoring for all die Los Angeles regional
watersheds. Iowa received $25,000 to develop a Statewide monitoring strategy which will reflect
the program needs of NPDES permits, non-point source controls, TMDL/WLA, and support a
watershed based approach to water quality management
-------
4.4 Prra *1™ an Fnvironmental Indicators
The Regions recognize the need for measures of success that better demonstrate the progress of
Watershed Approach implementation and the environmental gains and successes within specific
watersheds and on a national basis. There did not appear to b« a consistent view, however, of
what the short and long term measures should be. One Region plans to hold an internal retreat to
discuss use of the 33 environmental indicators developed by the Office of Water. This Region
believes that environmental measures need to be tailored to each watershed and expressed in clear
terms that the public can understand. Two Regions indicated that the State Assessments and
Regional Action Ptam could servao benchmarks for progress. Another Region has selected four
"indicator basins" which wilt be evaluated against a comprehensive set of measures. At least two
Regions expressed concern regarding the planned use of "loading reductions" as a national
environmental indicator for several reasons, such as data quality and ta* marginal nature of the
remaining reductions. One Region suggested that future Branch Chiefs' meetings may be a good
forum in which to discuss the development of national programmatic measures of success.
4.5 Public Participation
All Regions understand the importance of and need for effective public participation throughout
the watershed assessment and implementation process. Several Regions have begun to undertake
new or changed actions to improwpublic participation and stakeholder inyqtvement In
Region 1 , Basin Teams have begun conducting public meetings with watershed stakeholders.
Region S intends to build on the public participation experience gained from development of
RAPs and LaMPs. Region 10 is frequently called upon to facilitate stakeholder involvement and
has also awarded 104(bX3) grants. tm> year for watershed councils. Region 6 has modified the
public participation process for NPDES permitting. Before holding a public hearing on a
proposed permit, the Region invites the public to an informal question and answer session. At
least one Region expressed concern, however, that increased public participation may not lead to
efficiency in the permit process or better, quality permits.
46 Enforcement
The NPDES Watershed Strategy encourages a watershed approach to enforcement This
approach includes emphasizing enforcement for both major and minor NPDES dischargers in
selected watersheds and using enforcement authorities to correct violations by dischargers that
are causing th? greatest degradation in a basin or watershed. A few Regions are implementing
their own watershed approaches to enforcement and supporting their States in doing the same.
Region 10 supported the Oregon Department of Agriculture (ODA) in obtaining l04(bX3) grant
funding for a watershed enforcement initiative. ODA is conducting enforcement initiatives in
three separate watersheds in western and southern Oregon that fail to meet water quality
standards. ODA intends to raise compliance awareness among Confined Animal Feeding
Operations (CAFOs) that are significant sources of pollution to these watersheds. This work
augments the existing statewide complaint-driven enforcement program. By targeting a small
watershed in each of three regions of the State, ODA will increase compliance awareness in the
regulated community while maintaining local technical capabilities.
-------
Region 3 is implementing the Environmentally Targeted Enforcement Strategy. This strategy
utilize* State-generated information in the Waterbody System to identify waterbody segments
impaired by point source discharges. The Region uses information from Permit Compliance
System (PCS) and from State data bases on both major and minor point sources in those
waterbodies to identify potential linkages to water quality impairments. Contributing facilities
are potential enforcement candidates if violations (Significant Noncompliance or other, non-SNC,
violations) are found, or may be candidates for further scrutiny of their NPDES permits.
Region 2 was able to convince the New York State Department of Environmental Conservation
that more than major point sources were contributing to water quality impairment in the reservoir
system nortLof New York City. NYSDEC now focuses on minors within the watershed and has
committed resources to input effluent monitoring reports for minor dischargers into PCS.
5.0 Issues and Needs
During the mid-year visits, each Region was asked to identify issues they felt may impede and
needs they felt would assist the implementation of the Watershed Protection Approach and the
NPDES Watershed Strategy. Additionally, the Regions were asked to comment on a potential
list of Headquarters action initiatives.
51 Issues
Summarized below are the top five issues that the Regions raised as an impediment to
implementing the Watershed Protection Approach. They are listed in descending order according
to the number of times they were raised by different Regions (the number is in parentheses). See
Appendix C for a complete list of the Regional issues.
Coordinated/Consistent Leadership at EPA Headquarters: (6) The primary issue with
implementing the Watershed Protection Approach is the lack of a coordinated strategy within the
OW at EPA Headquarters. As stated by the Regions, the NPDES Watershed Strategy attempts
to pull in all water quality programs, but is still fundamentally an "NPDES Watershed Strategy"
The Regions suggest that the Assistant Administrator needs to encourage all OW programs to
take a coordinated approach if the overall Watershed Protection Approach is to succeed.
Flexibility in Implementing the Watershed Protection Approach: (5) Flexibility was raised as an
issue in relation to several aspects of the NPDES Watershed Strategy. For example, the decision
about whether to implement a Statewide basin management approach or targeted approach
should be afforded to each State. A Statewide basin management approach may not be feasible in
States with drastic differences in hydrology, population distribution, and land ownership (e.g.,
80% of Nevada lands are owned by federal agencies or Indian Tribes). States that decide to
impJement a Statewide watershed protection approach, should to be allowed to move at their
own pace. Additionally, States and Regions need to have permission to fail and to learn from
those failures as well as the successes. The timing for implementation was also raised as an issue.
Regions felt that the time frame between the final Strategy (March 1994) and State Assessment
Guidance (May 1994) and the due date for State Assessments and Regional Action Plans
-------
^September 1, 1994) was not feasible given available resources and present fiscal year 1994
commitments.
Multiple Agenda or Regional Offices within States: (3) The coordination required for effective
implementation of a basin management approach, such as agreement within the State on a
framework for basin management, can be difficult where water resource management programs are
divided among different State agencies. In addition, States which have regional offices often
create the appearance of separate States, each with their own water quality programs and
watershed efforts.
Lack of Statutory Authority. (2) Implementation of the NPDES Watershed Strategy would be
simplified if the Approach were specifically authorized in the Clean Water Act (CWA); Regional
implementation of the NPDES Watershed Strategy can be difficult since it is voluntary on the
part of the States, especially in authorized States.
Consolidated Grant and Reporting Requirements: (2) Multiple reporting requirements on
different reporting cycles were listed as an impediment to effectively implementing the
Watershed Protection Approach. Specifically, Regions identified the need to consolidate §303(d)
and §305(b) reporting requirements. As a first step towards grant consolidation, it was
recommended mat Headquarters enable the Regions to make §319 and § 104(bX3) grant decisions
at the same time.
5.2 Needs
Summarized below are the top five needs that the Regions stated were important to their efforts
to implement the NPDES Watershed Strategy and the Watershed Protection Approach. See
Appendix C for an overview of all the needs that the Regions expressed.
Additional Resources and Contract Support (9) Most Regions stated that present resource and
staffing constraints will hinder the full implementation of the NPDES Watershed Strategy.
Regions indicated they do not have the necessary travel funds or contractor support to provide
adequate guidance and outreach to States on implementing the Watershed Protection Approach.
Additional resources, both EPA positions and contract support, are needed to complete
comprehensive assessments and action plans for States, develop State framework documents,
conduct watershed training to expand State monitoring capabilities, and develop GIS capabilities.
Data Management/Integration: (8) Most Regions also indicated that EPA needs to play a more
aggressive role in addressing data management issues since high quality, reliable data is necessary
to effectively implement the NPDES Watershed Strategy. Several Regions identified specific
areas where discharger data is either suspect or non-existent (e.g., PCS, STORET). Where data
does exist, it often does not integrate well with other data management systems (i.e., GIS). At
this rime, several Regions do not use USGS basin codes in PCS and conversion to these codes is
essential; there is question as to whether PCS can accommodate entry of USGS basin codes for
minor discharges.
10
-------
HQGiridance/rratnfng: (6) EPA Headquarters snouia serve as a clearinghouse and trainer to
promote technology transfer and to communicate watershed protection successes:
Provide case studies whkh document specific aspects of State watershed
protection approaches including: alternatives for dealing with permit
synchronization and backlogs, th&cost effectivenesr of existing approaches, and
changes in the level of effort and efficiencies realized in various program areas
(e.g., ambient monitoring);
Conduct workshops for Regions and States which present the concepts of basin
management; provide technical guidance to support implementation of the
NPDES Watershed Strategy on areas such as alternative permitting mechanisms,
ambient monitoring, and coordinating NPDES permit development with TMDL
prioritization; and
Sponsor a national meeting involving Regions and States across several water
programs to discuss issues related to development and implementation of
comprehensive watershed protection programs.
Refinements to Accountability Systems (Strategic Targeted Activities for Results System (STARS)
and Office of Wastewater Enforcement and Compliance Accounting System (OWECAS)): (5) The
Regions recommend that Headquarters' accountability measures be revised to reflect the emphasis
being placed on implementation of the NPDES Watershed Strategy; continuing the use of
accountability measures that are not aligned with the Strategy does not reinforce the message that
the Permits Division is committed toonpiementing the NPDES program on a watershed basis.
Several Regions proposed that accountability measures be revised to reflect a qualitative, or
narrative nature. Program measurement discussions that focus on number of permits issued and
the administrative distinction between majors and minors have become too much of an institution
and are not representative in the context of watershed protection.
Finally, EPA Headquarters' expectations and program measurements should take jnto
consideration a period of transition (e.g., decrease in permit issuance, learning curves, and
coordination issues with other programs). States and Regions must also have "permission to fail"
and I earn from failures as well as successes.
Coordination with OECA. (3) Full coordination with and buy-in to the Watershed Protection
Approach by the Office of Enforcement and Compliance Assurance (OECA) is essential;
compliance assessments, enforcement reviews and enforcement actions are almost exclusively
based upon a facility being classified as a major discharger. The lack of information for minor
dischargers impedes and limits the ability to deal with all NPDES facilities within a watershed.
.AJd/tionally, it was suggested that OWM initiate actions, as part of the curent actions underway
to negotiate a memorandum of agreement with OECA on PCS, to address the data
management/integration needs to support the transition of the NPDES Program to a watershed
approach.
11
-------
S 3 H*adgy,ajtent Ini nlcnientatifMi Plan Feedback
Regional staff md management were presented with a list of 26 action items that EPA
Headquarters could undertake to support the Regions in implementing the NPDES Watershed
Strategy. Each Region was asked to select the top five activities that they felt would be most
helpful to them. Summarized below are the top six EPA Headquarters1- Action-Kerns that the
Regions voted to have Headquarters undertake. See Appendix.D far more details on how each
Region voted on the complete list of potential Headquarters' Action Items.
Regulatory/Policy Support for the Strategy:(ft) Evaluate impediments to implementation of the
NPDES Watershed Strategy as a result of the existing regulatory and policy framework.
Consider changes that will foster implementation.
Data Integration (PCS, Storage and Retrieval of Water-Related Data (STORET), Toxics Release
Inventory System (TRIS), Waterbody Systems):^) Evaluate current data bases and data
management systems to determine how they should be used (i.e., data integration) or updated to
better support a watershed approach to NPDES permitting. Work with OECA to evaluate and
make changes to PCS that better support the Strategy.
Coordination with OW Offices andOECA'Q) Communicate with me Office of Wetlands,
Oceans, and Watersheds (OWOW); Office of Science and Technology (OST)r Office of Ground
Water and Drinking Water (OGWDW); and OECA on NPDES watershed activities to gain their
needed cooperation and support
Conduct Regional Workshops:^) Conduct traln-jhe-trainer workshops for each Region in order
to facilitate watershed protection training (concepts of basin management and the NPDES
Watershed Strategy) for individual States,
Oversight: Revise STARS and OWECAS Criteria to support Watershed Implementation: (4)
Establish revised measures that demonstrate progress.by Regions and States to implement the
NPDES Watershed Strategy and integrate the NPUEs ATogram and BM Watershed Protection
Approach.
Watershed Matrix Management: (4) Provide leadership and coordination to achieve the
objectives of the NPDES Watershed Strategy.
6.0 Benefits of a Watershed Strategy
During the Regional visits, OWM asked the Regions to identify examples of environmental
progress which result from the application of a watershed strategy to address existing issues or
problems. Regions also identified areas where they expect that a broad-scale watershed strategy,
such as a Statewide basin management approach, will prove beneficial to the environment and to
Regional and State agencies.
12
-------
6 1 Potential Benefits, of an Overall Watershed Strategy
Regions and States have identified and, in some cases, experienced a number of benefits
associated with operating by a broad-scale watershed strategy such as the basin management
approach. Some of these benefits are as follows:
Improved Basis for Management Decisions: A watershed strategy can improve the scientific
basis for decision making and focuses management efforts on basins and watersheds where they
are most needed. Some Regions believe that bolh point and nonpomf control strategies will be
more effective under a watershed approach because the approach moves States toward timely
and complete development of TMDLs. One Region stated that a watershed-based decision
process will help resolve issues related to apportionment of loadings, assimilative capacity of
streams, antidegradation, and other historically difficult permitting issues.
Enhanced Program Efficiency: A basin focus can improve the efficiency of water management
programs by facilitating consolidation of programs within each basin. For example, one Region
noted that handling all point source dischargers in a basin at the same time should reduce
administrative costs due to the potential to combine hearings and notices as well as allowing staff
to focus on more limited areas in a sequential fashion. Another Region is encouraging one of its
States to use basin plans as an efficient means for meeting the CWA mandates for §305(b)
assessment and §303(d) listing of waterbodies.
Improved Coordination Among Programs: Regions and States have found that as they begin to
focus on river basins, rather than the programs operating within those basins, they are better able
to participate in data sharing and coordinated assessment and confrol strategies. Several Regions
demonstrated improved coordination among their programs through the process they used to
prepare for the OWM visit and to develop their Internal Strategies, State Assessments, and
Regional Action Plans. Regions have formed teams for these tasks that often include program
staff from across the Water Management Division and from other divisions as well.
Greater Consistency and Responsiveness: Developing goals and management plans for a basin or
watershed with stakeholder involvement should allow Regions and States to be responsive to the
public and consistent in determining management actions. Stakeholders'can expect improved
consistency and continuity in decisions when management actions follow a basin plan. One
Region noted that environmental justice issues should be more completely addressed since there
will be more comprehensive and complete examination of environmental stressors involving all
stakeholders in a basin.
62 Example^ flf Watershed Successes
The Regions provided examples where watershed strategies promoting integrated, resource-based
decision making are helping to address specific management problems and to resolve NPDES
permitting issues. A few of these examples are highlighted below:
Long Island Sound: Region 2, New York, and Connecticut agreed to control the discharge of
nitrogen into Long Island Sound in order to reduce eutrophication and improve on the low levels
13
-------
of dissolved oxygen in bottom waters By bringing the stakeholders together and focusing on
environmental problems backed by data, the States focused on freezing nitrogen loadings from all
point sources. In one instance, Westchester County, New York has explored ways to obtain
reduction in nonpotnt source nitrogen loadings in order to provide capacity for increased loadings
at POTWs.
Geographic Information Systems: Region 3's Water Management DUOJUJB (WMD) is leadtag *
pilot effort to use environmental data to guide decision making and priority-setting in the Region.
The Region has successfully used geographic information systems (CIS) to develop Regional
strategic objectives. For example, by aggregating data from the Waterbody System up to the
watershed level, the WMD's GIS specialist and other scientists were able to look at the cause of
water quality impairment throughout the Region on a watershed basis. They found that acid
mine drainage was causing significant water quality problems in most watersheds in the western
part of the Region. As a result of this GIS work, addressing surface water quality problems
associated with acid pollution became part of the Region's Strategic Plan. GISTtfso has been used
to assist in the planning and implementation of geographically targeted efforts such as the
Christina River basin interstate project; the identification of point sources in waters of concern
for endangered species in Pennsylvania; and the location of living resource areas of concern in the
Chesapeake Bay.
Remedial Action Plans andLakewide Management Plans: In Region, 5. Remedial Action Plans
(RAPs) and Lakewide Management Plans (LaMPs) serve as watershed management plans
addressing stressors which impact, or have the potential to impact, the beneficial uses of the
Great Lakes, including stressors such as point and nonpoint sources of pollution, critical habitat,
and exotic species. Implementation of the plans is based upon application of base programs such
as the NPDES program. Although RAPs and LaMPs are not by themselves reflective of an
entire change to a State's program, they reflect the coordinated results that may occur once a State
reorders its program on a watershed basis.
Storm Water Permitting: The State of Washington is developing a watershed-based municipal
separate storm sewer system (MS4) permit The MS4 permit is expected to cover every
municipal storm sewer system, regardless of size, in the Greea/Duwamish and Cedar River
basins. These basins encompass Seattle and approximately 99 percent ofKing County, including
some smaller municipalities.
7.0 Summary
The NPDES Watershed Strategy issued in March 1994 represents a statement of
commitment and an action plan for moving the NPDES program to a Watershed and Ecosystem
Approach. In a further demonstration of commitment to the Strategy and the Watershed
Approach, the Office of Wastewater Management fundamentally changed the focus of the Region
,-
-------
Table of Regional and State Watershed Contacts
Appendix A
-------
1
I
1
1
1
1
1
1
1
2
2
3
3
3
3
3
3
3
3
4
4
Regional Lead for
Watershed
Lmp ifi SiCtUBjo u
Resource Protection
Specialist
NPDES Watershed
Lead
Lead Coordinator -
CT
Lead Coordinator -
MA
ifM\ Coordinator-
ME
Lead Coordinator -
NH
Lead Coordinator -
RI
I /*-3yj Coordmator -
VT
Regional Watershed
Coordinator
NPDES Watershed
Lead
Regional Watershed
Protection Leads
NPDES Watershed
Lead
NPDES Watershed
Contact -DE
NPDES Watershed
Contact -DC
NPDES Watershed
Contact-MD
NPDES Watershed
Lead -PA
NPDES Watershed
Contact - VA
NPDES Watershed
Contact-WV
Regional Watershed
Coordinator
NPDES Watershed
Lead
David Fiern
Rosemary Monchan
Kevm McSweeney
Mel Cote
DeogCorb
C. Kilbride
S. Sadcer
Mkhele Notanam
Doug Co rb
D.Luciano
Joanne Sulak
L. Stepphacher
RjckBalla
PatDurack
Joe Piotrowski
RichPepino
VickiBinetti
Leo Rssenthier
Kevin Magexr
ArmCarkhuff
Kristine Matzko
Elaine Harbo Id
Fransisco Cruz
Richard Paiste
Meredith Anderson
Jim Patrick
Water Management
Division Director
Environmental
Scientist
Permits Branch
Chief
CT Permit Coord.
Env. Prot Spec.
Env. Engineer
Env. Scientist
ME Permit Coord.
Env. Engineer
3 19 Coordinator
T jJre Phamplain
Coordinator
Water Quality
^" flnftffff^^^^t Section
Chief, Water Permits
and Compliance
Section
Chief, Water Quality
Chief,
A ac^ccfT^ntf Rrarv*h
Chief, Permits
Enforcement Branch
Wetlands, Ocean,
and Watershed
Branch
Chief, Permits
Section
(617) 565-3478
(617)565-3518
(617) 565-3560
(617)565-3519
(617) 565-3514
(617) 565-3573
(617) 565-W86
(617)565-3519
(517)565-9130
(617) 565-3523
(617) 565-4874
(212) 264-5671,
(212) 264-9894
(215) 597-9077
(215)597-1181
(215)597-6511
(215) 597-0547
(215)597-1651
(215) 597-9406
(215) 597-7938
i215) 597-0547
(215)597-8813
(215)597-6539
(404)347-2126
ext 6581
(404)347-3012
(617)565-4940
(617) 565-4940
(617)565-4940
(617)565-4940
(617)565-4940
(617)565-4940
(617)565-4940
(617) 565-4940
(617)565-4940
A-2
-------
5
5
6
6
7
7
7
7
8
9
9
9
9
9
10
10
Region*! VfrteKted
Coordinator
NPDES Watershed
Lead
Regional Watershed
Coordinator
NPDES Watershed
Lead
Regional Watershed
Coordinator
Nonpoint Source
Watershed Lead
Monitoring and
Water Quality
Watershed Lead
NPDES Watershed
Lead
Wetlands Watershed
Lead
Regional Watershed
Coordinator
Regional Watershed
Coordinator
Nonpoint Source
Monitoring and
Water Quality Lead
NPDES Watershed
Lead
Wetland! Watershed
Lead
Watershed Manager
NPDES Watershed
Coordinator
Name
DougEhorn
Steve Jam
Luci English
Stephen Bainter
Donna Sefton
Julie Elfving
John Houlihan
DonToensing
** *u
Karen Hamilton
Dave Smith
Jovita PaiajUlo
Phil Woods
Terry Oda
Steve Paidieck
Ron Lee
Paula VtnHaagen
Title
Watershed
Coordinator
Permits Section
WaBy M»"jtf"""*
Division
Planning «v|
Evaluation Section
Planning and
Evaluation Section
Chief
Permits &od
Compliance Section
Chief
environmental
Review, Chief
Water Quality
Branca
Watershed Protection
Coordinator
NPS Coordinator
Water Quality
(vOoroinaiof
Chief, Peiuuti
Section
Oaef, Watershed
Protection Branch
Tefenboae
(312)886-0243
(312)886-2446
(214) 655-8022
(214)655-7537
(913)551-7500
(913)551-7475
(913)551-7432
(913)551-7446
(913) 551-7573
(303) 293-1576
(415) 744-2019
(415)744-2011
(415) 744-1997
(415) 744-1923
(415) 744-1953
(206)553-4013
(206) 553-6977
(214)655-6490
(214)655-6490
(913)551-7765
(913)551-7765
(913)551-7765
(913)551-7765
(913) 551-7765
(415)744-1078
(415)744-1078
(415)744-1078
(415)744-1873
(415) 744-1078
A-3
-------
State
AK
AR
AZ
CA
CT
HI
IA
ID
IL
IN
KS
LA
MA
ME
MI
MN
MO
NE
NH
NPDES Wiiteiiued
Contact
NPDES Watenhed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watenhed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watenhed
Contact
NPDES Watenhed
Contact
NPDES Watenhed
Contact
NPDES Watershed
Contact
NPDES Watenbed
Contact
NPDES Watershed
f>rt?*ct
Doug Redb urn
Carl SffiTO
BnuLMonmL
JeffBarncoV
JetseDiaz
Ed Parker
Dr. June Harrigan
DaneS
MacAllister
IfWfl^ffnAg
Tom McSwigpo.
CathenneHetf
Steve Rooach
KatfMjeldener
Emerjie Cormier
PanlHogan
Mickey KohDt
Bifl McCracken
Laurie Maniraon
JohnMandnu
Steve Walker
Ray Carter
TItk
Department of
Envuonmeatol
Conservanon
Director, Water
Quality Division.
ADEO
Division of Water
Quality, State water
Resonices Control
Board
Director, Bureau of
Water Management
Ouei;
Environmental
Planning Office,
HDOH
BnreadofSunace
and Ground Water,
Chief
Division of
n-nvrFffimtdiud
Quality
Bureau of Water;
Chief
Pemnts/Water
Quality Specialist
Director, Bureau of
Water Quanry
Control, Director of
Lie. Enfor. Field
Services
Water Planning
Section, Chief
Surface Water
Quality Section
Administrator
Teknhooe
(907) 465-5303
(501} 682-3779
(6TO) 207-2303
(916)657-0939
(916)657-0756
(203)566-7132
(808) 5864338
(551)281-8869
(208)3344407
(913) 296-5502
(504)765-0511
(508)792-7470
(207)2*7-7814
(314)751-7428
(402)471-4227
(603)271-3503
Fax
(3U1J 682-3991
(602) 207-4528
(916)657-2388
(203) 566-8650
(808)586-4370
(515)281-8895
(913)296-5509
(504) 765-0635
(508) 839-3469
(207)287-7826
(314)751-9396
(402)471-2909
(603)271-3456
A-4
-------
State
NJ
NM
NV
NY
OH
OK
OR
RI
TX
VT
WA
WI
•NPDES Watershed
Cootact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
NPDES Watershed
Contact
Name
Narinder Ahuja
Susan Hill
Wendell McCuny
Albert Biomberg
Paul Novak
Sylvia Ritsky
AndySchaedel
A.Liberti
Wendy Gordon
B.Kooiker
DaoWrye
SueHoppa
Tide
Assistant Director,
Division of Water
Quality
Bureau of Water
Quality. NDEP
Chief; Water Quality
Evaluation Section
Demitment nf
Environmental
Quality
Supervisor Sanitary
Engineer
Chief, Discharge
Permit Section
Deportment of
Ecology
Telephone
(609) 292-0407
(505) 827-2792
(702) 687-5883
(518)457-4352
(405)231-2691
(503)229-6121
(401)277-6519
(512)463-8448
(802)241-3822
(206) 407-6459
Fax
(505) 827-0160
(702) 885-0868
(405)231-2691
(401) 521-4230
(512)475-2454
(802) 244-5141
A-5
-------
Table of State Progress and Highlight*
Append ixB
-------
Sttfe
Completion
SA RAP
HlgtHfta/Profnu of State A*tessme»t»
CT
9-1-94
9-1 -94
Watenhed implementation is in the developing stage*. Letter to
State from WMDD to open formal watershed dialogue was signed on
Junfc 10,1994. State experience with Long Island Sound ptovides an
eutiee to the watershed approach.
MA
9-1-94
9-1-94
The State initially punned a watershed approach because of metal*
issue* and oat of a desire to coeidinate water withdrawal permits.
Sale established an Office of Watershed Management about one year
ago. State has established a three year basin cycle: year one for data
collection; year two for data review and TMDLs; and year three for
permit issuance. Region and State are setting permit cycles so
pennita wiitbe batin aligned in
9-1-94
9-1-94
Extensive progrtai by the State and Region to deli orate basins
within the State and plot location* of »fl major point sources using
GIS. Planning cycka have been established for each basin and for all
major NPDES permits.
NH
9-1-94
9-1-94
State agrees m principal with the Watenhed Approach. A state
watershed coordinator is expected to be L initiative provide an entree to the watershed approach.
VT
9-1-94
9-1-94
Watenhed implementation is in the developing stages. Letter to
Stale from WMDD to open formal watershed dialogue was signed on
Jane 10,1994. State experience with Lake Champiain Study
NJ
9-1-94
9-1-94
The Region has been working with New Jersey overall the last six
months in a strategic planning process. New Jersey is developing an
overall watershed strategy which is expected to include a five year
The Stale **** identified hastnt E"1 is developing
QpJ£
State A
ntation rales. The Region expects to be able to complete the
and Regional Action plan by September 1, 1994
bated on its current knowledge of the State* efforts. The State
Assessment is viewed as an internal exercise and as a critique of the
State's strategic plan. The Regional Action Phut is likely to foster
additional analysis and evaluate the elements that are missing or not
ratty developed, such s* data coordination, measures of success and
public participation.
B-2
-------
Region State Completion
SA RAP
HigUighU/Profress of State Assessncats
NY
9-1-94
Toe Region has been wonting wdh New York over the last two yean
onasdategicpian. The TY 94/FY 94-95 Strategic Plan for New
York State" was completed in December 1993. This document is an
update of the September 30. 1 992 version of the Strategic Plan for
New York, The overall intent of the Strategic Plan is "to f ocas
resources in targeted areas with definite 8£QQB^iCBUlt3 to be
achieved*. The Plan focuses on three
credibk base program; watershed-based targeting; and
g»rtv»nt of contaminated ff^tinynty and dredged material The
process focused on kkntifying majot/stgnificant issues on a statewide
basis and was not intended to comprehensively identify all problems.
The-plan includes lists of State targeted waters and other selected
wneibodies in matrices and shows use impairments, •p*"** of
*s, sources of pollutants, and the primary control programs
for each of the wateibodks, The Plan also includes the base program
Strategies and aperijl initiative^ that «n» ifafiynft] fa afM"?ffff the
problems in the specific waterbodies. The Region expects to be able
to complete the State Assessment and Regional Action plan by
September 1, 1994 based on its current knowledge of the State's
efforts. The State Assessment is viewed as an internal exercise and
as a critique of the State's strategic plan. The Regional Action Plan
is likely to foster additional analysis and evaluate the elements that
are missing or not ftiQy developed, such as data coordination,
measures of success and public participation.
PR
9-30-94
9-30-94
The Region met with the Puerto Rico Environmental Quality Board
On June 29, 1994 and received an tgi
n
FY95. Puerto Rico has no written watershed strategy at this time,
bat the Region expects to complete the assessment and Regional
Action Plan by September 30, 1994. The Region has begun to look
at permitting priorities and to consider p& mining strategies tin* may
gain some program efficiencies. The Region is also working on
getting Puerto Rico to consistentiy provide water quality
certifications.
VI
Not
Planned
Not
Planned
The Region believes that an assessment and Regional Action Plan are
not needed for the Virgin Islands for several reasons: limited
geographic area, few point sources, no discemibk watersheds; and
concern about VTs base program.
DC
FY95
FY95
The Region has formed a state assessment team for the District of
Colombia. No farther action has been taken.
DE
9-1-94
9-1-94
A preliminary assessment and first cut at an EPA Action Plan have
been prepared for Delaware, and have been forwarded to the State for
their review. Region 3 will meet with the state in Jury 1994
MD
FY95
FY93
The Region has formed a stale itf****™*** team for Maryland. No
further action has been taken. Maryland is currently developing and
implementing tributary strategies for its basins that drain to the
Chesapeake Bay. These strategies cover the majority of the State.
PA
FY95
FY95
The Region has formed a state assessment team for Pennsytvama.
The Commonwealth atttrrtptfid to implement a watershed-based
modeling and permitting approach in the late 1980s and early 1990s.
The approach met some resistance from Pennsylvania's regional
offices and was difficult to keep on schedule. Pennsylvania is now
attempting to implement a simpler watershed permitting approack
Because of the current action in Pennsylvania, Region 3 views it as a
priority state for developing an assessment and action plan.
B-3
-------
Region
3
3
4
4
4
4
4
4
4
4
5
5
5
5
State
VA
WV
AL
FL
GA
KY
MS
NC
SC
TN
IL
IN
MI
MN
Comptetioa
SA RAP
FY95
FY95
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
ISTQTR
FY95
ISTQTR
FY95
ISTQTR
FY95
ISTQTR
FY95
FY95
FY95
9-1-94
9-1-94
9-1-94
9-1-94
9-1^94
9-1-94
9-1-94
9-1-94
2NDQTR
FY93
2NDQTR
FY95
2NDQTR
FY95
2NDQTR
FY95
Hightighta/Progress of State Assessoeats
The Region has formed a state assessment team far Vtrgmu The
Region is delaying action in Virginia nndl trandhnm in State
government are complete. Region 3 views coordination of the point
source and nonpoint source umgiaiin, which are manaj^j in two
separate agencies, as particularly challenging. Also, Virginia hat
identified 9 maior river bfins fbr the mint source nrrwnm fowl nn
basin plans begun in 1972) and 461 basins for the nonpoint source
programs on some watersheds and in developing the State 303(d) list
which was referenced to the nonpoint source watersheds.
The Region has formed i state assessment team for w«o Virginia
The State is enthusiastic aboot the basin management appmnch and
would benefit from assistance in developing • de**ii?4 n«dmta«1ing
of the approach and constructing a framework document A particular
cbalknge is that the key programs are split between West Virginia's
natural resource and water resource agencies.
AL is interested in WPA, but wants to take it slow. The State
prefers to start with a geographical targeting approach and over the
iwt fivf VMTV mmn> il* lMll*iH«rk> r\f**fr tn • Ktxin rmnaa~m*nt
approach.
FL is the only non-authorized Region IV State. Eighteen months
ago the Region initiated discussions on the WPA with FL, but the
State was not interested FL now expresses some interest in
pursuing the WPA, however, may want to wait until the State
receives authorization for die NPDES program.
GA is actively engaged in the development of a State-wide watershed
framework document. A potential lawsuit for failure to develop
TMDLs for impaired waters is viewed as an incentive for the State to
pursue the basin management approach.
ICY has expressed interest in the WPA. but has taken no action to
date.
MS is interested in die WPA. The State received 104(bX3) money
for a pilot watershed project
approach. The State has completed the Neuse and Lumber basin
cycles and has started the Cape Fear basin.
SC is niiiy iTnp*cnw^**ff a pa (in "wiiafl^menst aopfoaciv i^c Ststc
has completed the Savannah Basin cycle.
TN indK*"* interest in the WPA. but has taken no action to date.
IL is currently interested in targeting problem areas. The State is not
the monitoring program is based on abasin cycle and the State
public notices their water quality management plan for basins.
IN three years ago divided the State into five regions which are
roughly aligned with the bydrological geographic basins. The State
established a five year sequence to assess each basin and to coordinate
permit issuance. The State is currently working in the Grand
Calumet area. The Stale process is not going as fast as they
originally planned, but is expected to get on track as a result of the
recent fee legislation and new staff.
MI is impl^n^nOng >**f basin management *ppmach in the poirjt
source program for Major and "significant" Minor dischargers. MI
has criteria to distinguish significant minors.
MN is interested in the WPA The State is developing a WPA
Strategy. The State grant program is based on basin olanninx.
B-4
-------
Refhm
5
5
6
6
6
6
6
7
7
7
7
8
State
OH
WI
AR
LA
NM
OK
TX
IA
KS
MO
NE
CO
CompktioB
SA RAP
1STQTR
FY95
1STQTR
FY93
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
2NDQTR
FY95
2NDQTR
FY95
9-1-94
9-1-94
9-1-94
9*44
9-1-94
9-30-94
9-3044
9-3044
9-3044
9-1-94
Hlghlights/Protress of State AjMiraieatj
OH initiated a hauled basin planning process for point sources in
1990. The State program consists of a five year cycle for monitoring
and WLA development The State is actively pursuing WPA on a
broader scale.
WI is developing a strategy, but it is not as comprehensive as the
conducting monitoring on a basin cycle, but does not coordinate this
effort with permit issuance.
AR has indicated that it is not pursuing a State-wide watershed
approach at tms time. It does, however, have two watershed projects
underway, including a joint study with OK on the Illinois River and
another effort on the Buffalo River.
promote public education about the Watershed Approach.
NM has a Water Quality Commission, which consists of
representatives from eight State agencies and three at large members
from the general public. The State is trying to improve its
relationship with Indian Tribes. To date, the State has targeted two
watersheds for its efforts: the Cinlinaa watershed and the San
Francisco and Gfla watershed. In the Gaiinat, nonpoint source
activities are the primary focus. In the San Francisco and Gila,
abandoned and inactive hard rock mines are the m»m concern.
OK has taken preJuninaty stepfctowards the development of a
responded to the State-by-state asscamirut questionnaire.
TX has begun a basin planning initiative which includes t set of
pilot basins for FY36anA a 10 year plan to address all basins in the
tyflAfl *T"Y tff tn tfat fMlvi •• nf n^fr fining itv H^tin* in nnr^r tn
the State serve as an avenue for funding projects. One such authority
is engaged in a monitoring project Another has prepared a series of
television commercials which suggest, "you dump it, you drink it*
Iowa submitted its FY 95 workplao which did not contain any goals
or objectives addressmst the watershed protection approach.
Kansas has reported that it is doing something on watersheds, but the
Region has not seen anything yet
Missouri is considering a targeted watershed approach where
resources are focused only on hi gfa priority watersheds in the State.
Nebraska is in the ewty implementation phase of i Sftte-wvie PM A
Nebraska has 13 «frK«»**H basins which are coordinated around a
five year cycle. First round of basin plans were due by 4/94.
Complete permit synchronization in all river basins is expected by
2005. Permits are synchronized under the BMA through the issuance
of 1 to 4 year permits to some dischargers. Public outreach activities
include distribution of written basin plans, public meetings targeted
according to basin cycle, water festivals, and stakeholder focus
xiuupt.
CO hat two active watershed groups consisting of several different
tfaJrchQldeif th>{ «re wnriring to addlCSt probkmf <" *e Upper
AitafMM Qnwr ai«4 PVar f if.rV nnrterct^yic TT* ^tfltfi hu DfeDflTtd 3
working paper that outlines a state-wide watershed approach and is
expected to adopt this approach formaUv in the near future.
B-5
-------
Region
8
8
8
8
8
9
9
9
9
10
State
MT
ND
SD
UT
WY
AZ
CA
HI
NV
AK
Compktkm
SA RAP
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
FY95
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
9-1-94
FY93
Highlights/Progress of State AssesaoKats
MT has developed a TMDL for the Clak Fork Sana for nutrients,
but is plaaaiog to impose limits on point soaroes only. The State is
patting all NPDES permittees affected by the Clark Fork TMDL on
the same peiiuilliiig cycle The point sources are expected to mam
atVtitmnal controls because noopout sources are not being controlled
in a comoolsory fashion.
ND is working with MN to develop a TMDL for the Red River of
the North, an interstate and international watershed. ND NPDES
permits on the Red River am being set tn expire yf the same Hme as
the MN permits across the river.
SD KM been slow in eontritoting to (he State assessment process
because of sensitive agricultural issues.
The Region believes that UT has demonstrated i enmrnitnv** %nd j$
making good progress toward developing a state-wide watershed
•rmnftfh TTT nlaiM tt\ (\pvpfan • ftvnwnrfc' ftrariirn^nit with frrant
assistance from EPA HQ The State ten little vthie in aligning tte
wocn ueceusVy.
There ii an effort going on in Crow Creek, which passes through tbe
fitv nf n^vgfifi^ TTv WY n^rLaitm^rrf t\f Fm/iirtnn^f^al Oiialirv
WY flame And Fkh, »nd (Jie CVyerme Board flfPubk? TftiliTie* 3"?
gathering Njyiim> data on the stream in an effort to delineate
problems and decide whether > classification upgrade is feasible
TTQlfC •• atan Heflvilv invnlvMi imctn*ftfn >f V(/amen Air Fnrrv R^ic^
All data is to be collected by the end of 1994, when it will be
decided if the stream classification will be upgraded and what
controls will be pot in place. A part of this effort will be a pilot CIS
study.
5ftong s*»t« nunmgemenj wpport ««d leadership for watershed
approach. Strong monitoring netwonc and CIS capability. Good
coordination in use of federal grants and State resources to target
funds.
Growing interest in watershed approach among State and regional
boards. Some excellent pilot projects underway. Over 100 locally-
limited* imfi"p]iHff ditt and analytical capacity for most watersheds,
Permits backlog substantial.
rnftfeqiutf? ftaff tn focns on watershed approach at this time Draft
strategy for a watershed protection approach, but only focusing oa
two priority areas now.
Already imr4*TT^ti*ing wHl «equenced standards to permits procca in
many watersheds. Able to use federal resources for watershed
assessment and planmn* due to full permit program funding by fees.
Watershed implementation in the State of Alaska presents a special
challenge hecaua; of the magnitude of the State1? geography, the
complexity of water quality problems, and a lack of exposure of the
State govemp^nt to details of the basin management •pprpach.
The Region expects to conduct training on basin management.
"nmn\ftf • ^tnt«» atK^nn^K inH dfvr-lnti A Rfinrtnnl artion ninn
with Alaska in fiscal year 1995.
B-6
-------
Region
10
10
10
State
ID
OR
WA
Completkm
SA RAP
9-1-94
9-1-94
FY95
9-1-94
9-1-94
FY95
FIgbWfhti/ProfrrM of State Aurssnmti
Region 10 completed the assessment for Idaho and developed an
action plan in April 1994. The uaaa incut and action plan will be
aihfaittMl tn PPA hv SmteabM I PB94 TTv Rnrinn1! rrrrrif nrf
in Idaho is ***** (he assesstBesfl ••^••imi plans *»fa* considerable
cflbtt. The primanr §HOBB «• iHting together the Regional and
••nnation into the assessmeit and action plan. Idaho plans to have
a framework document completetfin October 1994 and begin their
first basin cycle in approximately 18 months. Region 10 is
encouraging Idaho to use basin plans to meet or exceed the
reiiuireineitti for IMJJL Development AM g3u3(D) reporting.
Oregon if it the beginning naget of developing i State-wide basin
Cnmewodc document in summer 1994, but the Region expects that
this may not be enough time to complete the document The Region
expects to complete its assessment and action plan by September 1,
1994.
Wart*ng*°flt ha* 1*V»pt«4 • Sfel^viiip hajan management appmarh for
office in the State has 4r linnittd and prioritized basins and if
developing groups of permits around common TMDLs. The Region
identifies inclusion of nonpoint sources in the hasin approach and
increased levels of public participation as potential areas for
improvement in the Washington process.
B-7
-------
Table of Issue* and Needs
Appendix C
-------
IMU*
JoordinaCBoyConsistent Leadership at EPA 1 leanVpiartari
•lexibiSty in implementing the Watershed PratKbon Approach
^ultfpto agenda* or Regional Office* within Stale*
.ack of Statutory authority to Implement WPA
;oordinat*d Grants and Reporting Prooaaa
Strong regulatory program w esaentfeJ to adopt Watershed approach;
_ack of IntanMt among *oma Staw managan
Allow authority to Issue permits up to 10 yean
Implementing tha Watarshad Approach may taka mora time until
experience la gained and tha benefits am feataed
Concern with tha future of tha WPA * imptamantatton doaa not mutt In
Uncertain of tha role of NPOES Program In Regions watanhad approach;
itfle valua In integrating NPOES Program where baalna have only a few
joint source*, and where point sourcee are not the problem
.ack of authority to control Non-point eource* of pdutfon
.ack of adequate monitoring activities and reliable data ia an obstacle to
mplementation of watershed efforts
r MDL development may stow down tha permttting proceaa; permtts have
wen written wtthout the benefit of TMOLs for a tang time
Allow States to develop initial load reduction targets with whatever
*
6
5
3
2
2
1
1
1
1
1
1
1
1
1
i^
ji
If
•*.-?
V*
, $
~.H"
v^
xS»
s-W
^
^
:^
,x*
s^
<-^
sX1
j£
*.*. •*$.
^
:«v
\x~"
^
2
X
X
*i.
M,-
it :
.H.^
%( •>
•-Jl>
!¥•
^-Vi
^
•-.%\ "••
^w
^^
%X- sV1
%-J
^X'
^.\^
SfSV
:4*>
^t
P
,s-*Xi
--v
ss^--
4
X
X
X
s
X
X.
».—
x^-^
>VN^
;4.!\
>^
s>\-*
^ '
X«->i!
^x;
*x-Js
^\
^
Js>N
^
SI?
^
^5:
^\
•^
i^'o ••
•
X
X
:T:
X
•.-*•
s--:
^
I
X
X
X
•
y
X
|
;t
X
X
10
X
X
X
••*• • I
Need*
Additional Resources and Contract Support
)ata Management/Integration
HQ Guidance/Training
Refinements to accountability Systems (STARS and OWECAS)
Coordination wtth OECA
}ermit Streamlining; easier permit mooeVaenna; allow the Incorporation
imita/requirementa wtthout chemlcaJ specMc fcntts
HQ should develop environmentel indicatora
:lexibility to assign reaouroee to ooKroMng minor NPDES facfftles where
:hose facilities are primary source* of pofjton
Revise permit applicailons to include information on watershed
Targeting loading reduction goals would be a big step towards
•Measurement of environmental Impacts
TOM
*
9
8
6
5
3
1
1
1
1
1
Region*
w
•»-
^
•*
.^
^
*$<.
1
\
f .
>v\\
,^ir
-s^,
2
X
X
X
X
*%-;
X-i
sifei
:Jti«
'tit:
M-f.1* •
• \>* •
•^4;
J^,:
•S^A:
-X
^^
£••%.•.
s^ <•'
;V
4
X
X
X
X
X
#»
X
,X^
.,Jk.
^•vt<
>Ts^
Jv*
f^'.
^v
s;V
^
-^
\*-
v •>>;-
s X*
6
X
X
X
X
X
t
X
;Jt
••^;.
k
• *;:••'
X
t
X
X
4
X
X
X
10
X
X
C-2
-------
Action Items for NPDES Watershed Strategy Implementation
Appendix D
-------
#
1
2
3
4
5
6
7
8
9
10
11
Action (torn*
Regulatory/Policy Support for the
Strategy
Data Integration (PCS. STORET,
TRIS. NEEDS, etc.). Industrial
Facilities Discharge Database,
Coordinate PCS Work group
Coordination with OW Offices and
OECA
Conduct Regional Workshops
Oversight: Revise STARS and
OWECAS Criteria to support
Walenhed Implementation
Watershed Matrix Management
Develop Policy on Ambient
Monitoring
Develop National Policy to
Coordinate NPDES Permit
Development with TMDL
Priori fixation
Review Regional Internal
Strategies
Develop Alternative Permitting
Mechanisms
Reconsider Classification and
Priorities for Major/Minor
Designation
Description
Evaluate impediments to implementation of the NPDES Walenhed Strategy as
a result of the existing regulatory and policy framework. Consider changes
thai will foster implementation.
Evaluate all current data bases to determine how they should be used (i.e, data
integration) or updated to better support a watershed approach to NPDES
permitting. Work with OECA to evaluate and make changes to PCS that
better support the Strategy.
Commumcate with OWOW, OCT. OGWDW. and OECA on NPDES watershed
activities to gain their needed cooperation and support.
Conduct a one *» one and a half day train-lhe- trainer workshop for each
Region in order to facilitate Regional watershed protection training for their
individual States.
Establiah revised measures that demonstrate progress by Regions and States
In implement ih" NPDES Watershed strategy and integrate the NPDRS
Program and the Walenhed Protection Approach.
Provide leadership and coordination to achieve the objective* of the NPDES
Walenhed Strategy and the Permits Division's Walenhed Mission StalemenL
Develop a policy which identifies how the NPDES program will support
ambient monitoring efforts and clarifies relevant legal authorities.
Develop a policy which describes how the NPDES program win support the
development and unplernentatinn of phased TMDLs.
Establish a T*"f" *» rvw* and evaluate the strategies established by the
Regions to coordinate related functions in the Region such as ground water
drinking water, standards, monitoring, TMDLs, permitting and enforcement.
Develop guidance and policy (including possible regulation changes) lo
expand the use of alternative permit mechanisms (eg, general permits) to
support implementation of the NPDES Walenhed Strategy.
Evaluate and revise the existing major/minor classification to address
environmental impacts and watershed protection criteria.
Number
of
Votee
6
5
5
4
4
4
3
3
2
2
2
Region
1
j|f
yiyc
$:£
9-
m
li
IP
m
'•&'.-:;;•
m*
m-
W
8
^k-
W
•tff.
m
m
H
m&
•%?•:.
ft
•zm
'&•'•
m
2
X
X
X
3
'•.':•'•: : .'''
Jx
M
<%K
ii
•'•>.-''• : •
*? •'':•: {'•
fx
'$••••:•
4*
9
'&£'%.
•v.f.-y.$
'•* ':•/''
i*
^
X
5
x
*
9;
?$$••
•:;X
•' ''• •'
• ,:-• ':
ific
1
m
'«''•'• :
'-/.- ' '••
%*{
§
X
X
X
X
7
X
srtS
1
P
js?;:
•;;»•
I
•igf
lx
•*
'•/.•: •'•
:x
•^.
m
•
-------
Action HMTIS
Description
12
Guidance for Group Monitoring
Under NPDES Scenario (Ambient
Monitoring Coordination)
Develop guidance which deacnbea how die NPDES program can support
efforts 10 coordinate monitoring efforts among groups of discharges.
13
Describe Watersheds. m FormlA
DM the Form 2A mlemaking to commumcale the objectives of die NPDES
Watershed Strategy and indicate how die forms support dtese objectives.
14
Describe Watersheds in Form 2C
Use die Form 2C rukmaking to communicate die objectives of die NPDES
Waienhed Strategy and indicate how die forms support diese objectives.
15
Outside Outreach Activities and
Publicize Watershed Successes
Identify irT"rt"B'ri*t lo communicate die mission, objectives and
implementation progress of die NPDBS Watershed Strategy and obtain
communication strategy for die Strategy.
Regional Mid-Yew Reviews Lead
16
Conduct visits lo all ten Regions in fane and Jury. 1994. The primary
objective of die reviews is to evaluate progress in implementing die NPDES
Watershed Strategy. The visits will result in individual reports for each
Region and a national report.
17
Coordinate with RMES to
Implement Flexible Funding
Recommendations to Support WPA
Identify a Permit* Drvun
staff i
ober to participate on die RMES grant
work group (106 and 319 grant programs) lo ensure grant flexibility issues
such as applicatinn and reporting requirements are addressed.
18
Identify Ways to Use or Change d»
Public Partiriperion Piooaas
Review die current NPDES public pamcipaaai process lo identify possible
improvements which will better support NPDES Watershed Strategy
19
Modify die NPDBS Perm*
Application Pnoess to Support
NPDES Waienhed Strategy
Review and revise, as accessary, dw NPDES permit application process to
provkteihenaceaaary JnfonnatkMtos^yonpemutdavelo|«neotand
on a watershed basis.
20
Develop FY 95 Matrix Work Plan
Prepare a work plan (and revise at necessary) for NPDBS Watershed which
includes individual activities. FTE anocatifais. HIM frame
WPA 104(bX3) Oranu
21
waienhed crusria; track project milestones to ensure compliance with die
Review Regional Stale
22
Aaa
its and Regional Action
Plant lo Support Stales
stais a eam to revew, evauate an comment on assessments of Stale
NPDES program! and die Regions' PY 95 plans to assist States in moving lo
waienhed based approach for dw NPDES Program.
D-3
-------
y
!3
14
15
16
Ad ton Hsms
National NFLKS/WKA Meeting
Identify and follow through on
NPR Priorities for Permit!
Diviiion
Develop Train the Iraincr Malarial
Wok with UfcCA to Change toe
Definition of SNC k> Support
Walenhed ImpkanentMion and
Surface Water Priori be*
Description
Plan tor and coordinate an integrated national meeting with the NMJbii and
other key programs including water quality lUndardi. TMDL water quality
ipetialiiu. compliance and enforcement, and other key NPDES element*.
Review the 48 recomtnendaooni of the National Performance Review process
nltled to NPDBS permiu and determine which have relenoce M
implementation of the NPDES Waienhed Strategy; develop a MraMgy for
addreciini reicv«U neonnendiiioai.
Prepare tainint malenali far • one and a half day workshop which win
provide infonaatk* to Reg tonal and Stale penonnel on the concept* behind
the Basis Maasgejsaat Afpsostii sad she six NPDSS Wsteshsd S&rsssgy
component*.
Work with (JUCA 10 Identify Significant Non-Cpmpliano* (SNC) criteria
which nflect waknhad pmaction need* and nviM.tht SNC dkfairinn
accordingly.
Number
of
Votes
0
0
0
0
R»gbn
:-1:V
trf / '
w,
.%'
n
%
%
'/*n"
!
I
2
3
i^
'!?.
ty
$k
$
%&
i
f
1
?•:> i?
* if
4
5
'', '
£.
' ' $''f
6
¥«a^
?•
*
jli
>**
;
^
'^/
8,1 9
\\
*€j
m
i%.
1
iV
fr
x ;
/
/ '
10
S^HM
D-4
-------
UNITED STATES ENVfRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE Of
WATER
MEMORANDUM
SUBJECT:
FROM:
TO:
Moving the NPDES Program to a Watershed Approach
fY .• •
Michael B. Cook, Directoc/| 1 ^ i (-.a ' .1 !^
Office of Wastewater Management
Water Management Division Directors, Regions 1-10
I am pleased to transmit to you our report, Moving the NPDES Program to a Watershed
Approach. As explained during each of the 1994 Regional visits, the purpose of this report is to
summarize the status of Regional efforts to implement the NPDES Watershed Strategy and
highlight the various approaches used to develop State Assessments, Regional Action Plans, and
Internal Strategies. The Report capsuiizes the Regional views on issues, needs, and expected
benefits with regard to implementing the NPDES Watershed Strategy, and discusses the types of
activities Regions believe the Office of Wastewater Management (OWM) should undertake to
support Regional implementation of both the Strategy and the broader Watershed Protection
Approach.
The Report indicates that Regional' programs are making progress in implementing the
Strategy since it was finalized in March 1994. Nine of the ten Regions projected that they would
submit their Internal Strategies and completed State Assessments and Regional Action Plans for
39 States and Puerto Rico in September,.(.Assessments and Regional Action Plans for the
remaining 12 States and the District of Columbia are expected to be completed in FY 95. Each
Regional office has established some variation of an internal workgroup to serve as a focus for
Regional watershed protection efforts. These workgroups tend to have multi-program
representation from both the Water Management Division and Environmental Services Division.
The combined list of Regional issues and needs reflect common themes such as
coordinated leadership in the Office of Water (OW), and flexibility in implementing watershed
protection efforts. These common issues and needs are having an impact on our activities in
OWM. and are being shared with other OW Programs. I expect that they will also be considered
in upcoming management discussions.
-------
We hope that the Report promotes ideas and stimulates discussion across the Regions
and States. Please feet free to call me or Jeff Upe, NPDES Watershed Matrix Manager, at
(202) 260-5230 if you have any questions regarding the Report
Attachment
cc. Bob Perciasepe
Bob Wayland
Jim Elder
Tudor Davies
Permits Branch Chiefs, Regions 1-10
Cynthia Dougherty
MikeQuigiey
Ramona Trovato
Jane Ephrimedes
------- |