United States
Environmental Protection
Agency
Office Of Water
(4203)
EPA 833-R-96-002
March 1994
v>EPA NPDES Watershed Strategy
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
2 I 1994
OFFICE OF
WATER
MEMORANDUM
SUBJECT: NPDES Watershed Strategy
FROM:
TO:
Robert Perciasepe, Assistant Administrator
Office of Water
Water Management Division Directors (Regions I-X)
The purpose of this memorandum is to build upon the discussion about the
Watershed Protection Approach at our January meeting in Albuquerque, New Mexico, and
to provide more detail on key action items agreed to in connection with integrating the
National Pollutant Discharge Elimination System (NPDES) program into the Approach.
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 Approach 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. Its
implementation is critical for the improvement of water quality in the United States, and it
is therefore an essential priority for EPA's water program.
Several States have adopted a watershed protection approach and have been
implementing watershed protection activities for some tune. A number of other States have
more recently begun to develop watershed protection frameworks, and still others are
considering how they might do so hi the near future. We look to these States to share their
knowledge and practical experience in watershed protection implementation. The challenge
for EPA is to support and facilitate this process.
There are already a number of significant Watershed Protection and related efforts
being led by offices within OW, including the Office of Wetlands, Oceans, and Watersheds
(OWOW) and the Office of Ground Water and Drinking Water (OGWDW). OWOW has
worked extensively with EPA Regions and within EPA Headquarters to develop a
comprehensive approach to watershed protection and has worked with both the States and
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Regions to champion hundreds of individual watershed pilot projects. OGWDW's efforts
to protect vital ground water and drinking water supplies, most notably its support of
Comprehensive State Ground Water Protection Programs (CSGWPPs) and its proposed
Source Water Protection Program, reflect important related concepts. These concepts
include stakeholder involvement, integrated solutions to environmental problems, and
geographically based actions.
OW's goal is to fully integrate the NPDES program into the Watershed Protection
Approach. While the NPDES program hi several Regions has taken significant steps to
implement watershed protection activities, the program nationally is as yet a largely
untapped resource. The NPDES program occupies a unique position within the overall
water program, since it is both a key customer and an essential partner hi supporting other
OW program activities and achieving many of our broader water quality goals. In order to
take advantage of the NPDES program's knowledge and experience to support the
Watershed Protection Approach, EPA's FY 1995 budget submittal includes a substantial
and far-reaching redirection of water personnel and resources.
In the context of the larger OW Watershed Protection Approach, the Office of
Wastewater Enforcement and Compliance (OWEC) has been working over the past several
months with States, EPA Regions, and Headquarters offices to develop a specific strategy
for a closer integration of the NPDES program into the larger OW Watershed Protection
initiative. This strategy reflects the emphasis on watershed protection within the ongoing
Clean Water Act Reauthorization process and is consistent with key elements of Senate Bill
S. 1114 as well as the President's Clean Water Initiative. The key themes of the NPDES
Watershed Strategy are refocusing permit issuance, providing technical assistance,
continuing oversight activities, working with other key OW programs to build a stronger
watershed partnership, and supporting new and ongoing State watershed protection efforts.
Discussion
Over the past 20 years, the NPDES program has achieved significant reductions in
pollutant discharges to surface waters by focusing on technology-based, chemical-specific
standards and water-quality based permit requirements. More recently, the NPDES program
' has included whole effluent toxicity monitoring requirements and limits, as well as an
emphasis on 304(1) assessments and action plans. In addition to these activities, there are a
number of new initiatives including: stormwater, sewage sludge, combined sewer
overflows, implementation of additional national effluent guidelines, incorporation of
sediment criteria and biocriteria, and others. The challenge for the NPDES program is
managing new and existing efforts within the context of both limited resources and
environmental impacts that vary from State-to-State and Region-to-Region. The Watershed
Protection Approach provides an environmental management framework within which
baseline program requirements and newer initiatives can be integrated to cost-effectively
address remaining point source environmental impacts within a State's watersheds and
support other surface water and ground water activities.
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The attached Strategy addresses EPA actions that will ensure that the NPDES
program supports, facilitates, and implements this Approach. While the Strategy focuses on
key action items for the NPDES program, it also emphasizes critical areas in which the
NPDES program must coordinate its point source control activities with the efforts of other
OW offices. The Strategy reflects the recognition that, while the NPDES program will play
a central environmental protection role in a number of watersheds, in many other
watersheds, point sources will not represent the primary stressors. The NPDES program's
mam task in the latter watersheds will be to support and facilitate effective implementation
activities for meeting environmental objectives (e.g., monitoring, permitting, public
participation). '
As outlined at the Albuquerque meeting, the NPDES Watershed Strategy consists of
four parts: (1) an introduction; (2) a set of guiding principles for the Watershed Protection
Approach; (3) the purpose and objectives of the NPDES Watershed Strategy; and (4)
detailed strategy components. The Strategy components address State-wide coordination,
NPDES permits, monitoring and assessment, programmatic measures and environmental
indicators, public participation, and enforcement.
Kev FY 1994 Regional Actions
There are several key Regional actions which need our attention during FY 1994. I
would like to take this opportunity to provide more detail on three specific actions which
the Regions must complete by September 1, 1994, to begin implementation of the NPDES
Watershed Strategy hi FY 1995. These actions include:
Regional State-by-State Assessments and Action Plans - Completing .
assessments of Watershed Protection activities and needs in each State and, in
the context of that assessment, developing Regional action plans for
FY 1995 that identify how the Region will support and facilitate each State's
movement toward the Watershed Protection Approach;
« State/EPA Workplan Agreements - Including specific activities within
State/EPA workplans for FY 95 which will promote the central components
of Watershed Protection;
Internal Coordination - Developing integrated Regional strategies which
will describe the Regional decision-making processes, oversight role, and
internal coordination efforts necessary to ensure support for the Approach.
In assessing State watershed protection efforts, the Regions should evaluate the
status of each State's watershed protection approach in the context of the NPDES
Watershed Strategy and identify actions that the Region will undertake to support and
facilitate the development or implementation of a. comprehensive watershed protection
approach in each State. EPA recognizes that many States, particularly those which have
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only recently begun to consider developing a watershed protection framework, will move
toward implementation of the Watershed Protection Approach in an incremental fashion.
We intend to work with each State hi whatever way we can to ensure progress in each of
the Watershed Protection component areas outlined in the attached Strategy and to provide
each State the support necessary to achieve successful implementation of the Watershed
Protection Approach.
To assist the Regions hi this effort, OWEC has been working with both the Regions
and ASIWPCA to compile and analyze available information about the status of individual
State watershed protection efforts. We are providing this preliminary information as an
attachment to this memorandum. It includes a State watershed protection approach status
and component matrix and fact sheets for each State about which OWEC has been able to
acquire State watershed protection approach information. In addition to the OWEC State
assessment effort, OWOW has assessed watershed protection projects throughout the Nation
and has developed project-specific fact sheets for each State; the purpose of these fact
sheets is to support the exchange of watershed protection information and promote
technology transfer, this information will be provided to the Regions under a separate
cover.
An appendix to the Strategy outlines a range of suggested activities for the Regions
to consider hi developing their action plans to support State watershed protection
approaches and in negotiating their State/EPA agreements. This document is organized
according to the specific NPDES Watershed Strategy components. As additional assistance
to the Regions hi supporting their States, OWOW is currently developing a manual which
will provide guidance on developing State watershed protection programs. We will
distribute this guidance as soon as it is completed.
To assure overall consistency and coordination, I am requesting that each Region
provide a copy of their internal strategy, State-by-State assessments, and FY 95 NPDES
Regional action plans for supporting States to OWEC by September 1, 1994. I am asking
OWEC to work with other HQ offices to review the Regional internal strategies and action
plans hi terms of their level of specificity, interim milestones, and how well they reflect and
can be expected to implement the NPDES Watershed Strategy. If you have questions or
need further information about the NPDES Watershed Strategy, please do not hesitate to
contact me or Mike Cook. You should feel free to contact other OW Office Directors if
you have questions relating to other areas.
Attachments
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NPDES WATERSHED STRATEGY
INTRODUCTION
Overview of the Watershed Protection Approach
Watershed Protection Successes and Challenges
NPDES Program Role
//. GUIDING PRINCIPLES
III. NPDES STRATEGY PURPOSE AND OBJECTIVES
Program Integration
Support for State-wide Basin Management Approaches
7F. NPDES STRATEGY COMPONENTS
State-wide Coordination
NPDES Permits
Monitoring and Assessment
Programmatic Measures and Environmental Indicators
Public Participation
Enforcement
APPENDIX
Regional Action Items
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I. INTRODUCTION
The Clean Water Act (CWA) sets forth the goal of restoring and maintaining the
chemical, physical, and biological integrity of the Nation's waters. The CWA also
establishes a number of programs designed to achieve this goal. These programs address
water quality criteria and standards, establishment of TMDLs, monitoring, technology-based
and water quality-based point source permits, nonpoint source control, and wetlands
protection.
The challenges faced by these CWA programs are great. There are more than
200,000 point sources (including stormwater) requiring discharge permits. An even greater
number of nonpoint sources significantly contribute to pollution problems. Safe drinking
water supplies must be maintained and aquatic habitats must be restored and protected. In
a time of limited resources, these challenges require innovative solutions and cooperation
among all stakeholders. The Watershed Protection Approach provides the necessary
framework for meeting these challenges.
Overview of the Watershed Protection Approach
The Watershed Protection Approach represents EPA's renewed emphasis on
addressing all stressors within a hydrologically defined drainage basin instead of viewing
individual pollutant sources in isolation. It is not at new program competing with or
replacing existing programs; rather, it provides a management framework within which
baseline CWA program requirements, related public health concerns, and newer initiatives
can be integrated to cost-effectively address restoration and protection of aquatic
ecosystems. By focusing on the hydrologic basin, the Watershed Protection Approach
emphasizes all aspects of water quality, including chemical and physical water quality,
habitat quality, and biodiversity.
The Watershed Protection Approach emphasizes the involvement of all affected
stakeholders in a drainage basin. Those concerned about the watershed and those able to
take action to protect and restore aquatic ecosystems are involved in decision-making
processes together. The Watershed Protection Approach also provides a framework hi
which to implement the principles of environmental justice. Environmental justice must be
considered simultaneously with other environmental goals and objectives in a particular
basin.
Finally, the Watershed Protection Approach focuses on taking comprehensive,
integrated actions to address environmental priorities. The approach stresses the need for
teamwork at the Federal, State, and local levels to achieve the greatest environmental
improvements with the resources available.
Watershed Protection Successes and Challenges .
Within the Office of Water (OW) there are a number of significant ongoing
watershed protection efforts. The Office of Wetlands, Oceans and Watersheds (OWOW)
has the OW lead hi promoting a national Watershed Protection Approach. This approach
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stresses coordination between EPA and other key stakeholders to address watershed
protection in a comprehensive and integrated fashion. OWOW also works with States and
EPA Regions to champion hundreds of individual watershed pilot projects. In March 1993,
OWOW co-sponsored the highly successful "Watershed '93" conference in Alexandria,
Virginia. This conference featured numerous opportunities to exchange information on
proven and emerging watershed management techniques. OWOW's National Estuary
Program employs a watershed approach for protection of estuarine waters and serves as a
model for promoting the long-term involvement of all watershed stakeholders.
The Office of Ground Water and Drinking Water (OGWDW) is aggressively
pursuing a complimentary approach through its Comprehensive State Ground Water
Protection Program (CSGWPP),. Wellhead Protection Program and proposed Source-Water
Protection Program. The NPDES Strategy will be implemented in conjunction with these
programs.
In addition to EPA's watershed protection activities, a number of States have
adopted State-wide watershed protection approaches and have been implementing them for
some time. Many other States are hi the process of developing such approaches, and still
others are considering how they might do so hi the near future. EPA looks to these States
to share their knowledge and practical experience hi watershed protection implementation.
The challenge for EPA is to support and facilitate this process.
OW's goal is to fully integrate the NPDES program into the Watershed Protection
Approach, support development of State watershed protection approaches, and coordinate
watershed protection efforts with other Federal agencies, States, Indian Tribes, and local
communities. The full benefit of watershed protection can only be realized with the
cooperation and coordination of all key stakeholders.
NPDES Program Role
The National Pollutant Discharge Elimination System (NPDES) program occupies a
unique position within the overall water program, since it is both a key customer and an
essential partner hi supporting and achieving many of EPA's broader water quality goals.
The NPDES program traditionally has focused on chemical-specific technology-based and
water quality-based permit limits or requirements. More recently, NPDES permits have
included whole effluent toxicity monitoring requirements and limits. In addition to these
baseline activities there are a number of new initiatives underway including: stormwater
permitting; 'sewage sludge permitting; combined sewer overflow (CSO) permitting;
implementation of CWA §304(1); implementation of additional national effluent guidelines;
and incorporation of sediment criteria and biocriteria.
The broad range of NPDES functions and activities gives the NPDES .program a key
role hi implementing the Watershed Protection Approach. NPDES program staff are an
important source of "on the ground" knowledge about the environmental impacts hi many
watersheds. The NPDES Watershed Strategy discusses integration of NPDES program
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functions into the broader Watershed Protection Approach and areas for coordination with
other stakeholders to promote implementation of the Approach.
The NPDES Watershed Strategy is divided into four sections. This introduction to
the Strategy comprises Section I. Section II discusses principles that are common to any
watershed strategy and Section III states the purpose and objectives of the NPDES Strategy.
The heart of the NPDES Strategy is Section IV, which identifies six major watershed
strategy components. These components outline specific areas in which the NPDES
program can support the Watershed Protection Approach.
//. GUIDING PRINCIPLES
Development and implementation of any watershed strategy, whether at the national
or State level, should be based on certain common principles. Six guiding principles are
listed below. The NPDES Watershed Strategy is based upon these principles.
1. Watershed protection approaches may vary in terms of specific elements,
tuning, and resources, but all should share a common emphasis and insistence
on integrated actions, specific action, items, and measurable environmental
and programmatic milestones.
2. Related activities within a basin or watershed must be coordinated to achieve
the greatest environmental benefit and most effective level of stakeholder
involvement.
3. Actions relating to restoration and protection of surface water, ground water,
and habitat within a basin should be based upon an integrated decision-
making process, a common information base, and a common understanding of
the roles, priorities, and responsibilities of all stakeholders within a basin.
4. Staff and financial resources are limited and must be allocated to address
environmental priorities as effectively and efficiently as possible.
5. Program requirements that interfere or conflict with environmental priorities
should be identified and revised to the extent possible.
6. Accurate information and high quality data are necessary for decision-making
• and should be collected on an incremental basis; interim decisions should be
made based on available data to prevent further degradation and promote
restoration of natural resources.
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///. NPDES STRATEGY PURPOSE AND OBJECTIVES
The purpose of the NPDES Watershed Strategy is to outline national objectives and
implementation activities for the NPDES program to 1) integrate program functions into the
broader Watershed Protection Approach and 2) support development of State-wide basin
management approaches. The Strategy will be implemented consistent with CWA
requirements and is not intended to supersede or impede existing watershed protection
efforts; rather, it is intended to support ongoing State initiatives and supplement the efforts
of other environmental programs by identifying areas to which the NPDES program can
contribute and, thus, build a stronger watershed partnership.
Program Integration
A major challenge facing the NPDES program is managing its new and existing
efforts within the context of both limited resources and environmental impacts and priorities
that vary from State-to-State and Region-to-Region. By integrating its program functions
into the broader Watershed Protection Approach, the NPDES program can effectively meet
this challenge. Success in this process, however, will require program flexibility with an
emphasis on environmental priorities.
Program oversight, administration, and regulations are principal areas of the NPDES
program where flexibility is important for successful integration into the Watershed
Protection Approach. Oversight and administrative requirements and regulations that
impede such integration should be revised or eliminated, where possible.
A focus on environmental priorities allows the NPDES program to achieve the
greatest environmental benefit with the maximum efficiency hi use of resources. This focus
allows the resources dedicated to issuing and reviewing NPDES permits to vary depending
on the environmental impacts of each source. In addition, the compliance monitoring and
enforcement program, in conjunction with the permitting program, can be used to address
environmental priorities and further the objectives of the Watershed Protection Approach.
Support for State-wide Basin Management Approaches
In addition to program integration, another key goal of the NPDES Watershed
Strategy is to promote ecosystem protection by supporting the development of State-wide
basin management approaches wherever possible. The first step hi building such a State-
wide approach is developing a basin management framework. A State-wide basin
management framework is simply an operating structure that:
Identifies the roles and responsibilities of participating programs;
Identifies long-term programmatic and environmental goals as well as key
interim milestones;
• Divides the entire State into basins in order to focus and coordinate
management activities on a geographic basis (watersheds or sub-basins
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generally are grouped into larger management units defined by the State and
referred to as basins);
• Establishes a schedule for periodically evaluating the environmental condition
of each basin and determining what management activities will occur in the
basin; and
• Establishes a methodology for issuing NPDES permits in each basin based on
an overall assessment of environmental priorities.
The second step hi the process of building a State-wide basin management approach
is to focus on individual basins. The basin management framework ensures that each basin
within a State is evaluated to assess environmental priorities and is periodically revisited for
further evaluation. Once a basin has been evaluated, a State can pursue restoration and
protection of watersheds by focusing the appropriate program activities (e.g., monitoring
strategies, phased TMDLs, NPDES permits, nonpoint source controls) on the basin. The
level of effort given to each basin is determined by the available resources and the threats
to human health and the environment within the bzisin. It is unlikely that all basins within a
State will receive the same level of attention and investment of resources.
EPA recognizes that many States, particularly those which have only recently begun
to consider developing a basin management approach, will move toward implementation of
this approach hi an incremental fashion. The underlying premise of this Strategy is that
EPA Regions will work with each State to ensure progress in each of the areas outlined hi
Section IV of the Strategy.
In summary, there are five key objectives to successful implementation of the
NPDES Watershed Strategy. These five objectives are summarized as follows:
1. Review and revise NPDES program oversight, administration, and regulations
as necessary to eliminate or reduce impediments to integrating the NPDES
program into the broader Watershed Protection Approach.
2. Allow the resources and level of effort dedicated to developing and reviewing
NPDES permits to vary depending cm the environmental impacts of each
source (relative to other stressors) in: the basin hi order to achieve the greatest
environmental benefit with the maximum efficiency.
3. Use the compliance monitoring and enforcement program, in conjunction
with the permitting program, to further the objectives of the watershed
protection approach.
4. Coordinate with other key water quality management programs to develop
and implement State-wide basin management frameworks.
5. Support related program activities (e.g., monitoring strategies, phased
TMDLs, nonpoint source controls) that address priorities in individual basins.
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IV. NPDES STRATEGY COMPONENTS
The following components identify six essential areas which must be addressed to
fulfill the objectives and purpose of this strategy. Suggested Regional action items to
support these components are included as an appendix to this strategy. Where the NPDES
program is not the lead program for a particular component, the action items identify
specific areas where the NPDES program must coordinate with and support other OW
programs to further the development and implementation of the Watershed Protection
Approach.
1. State-wide Coordination
• EPA will work in partnership with States to support the development of
State-wide basin management frameworks; these frameworks should reflect
existing experience with programs such as 303(d), 303(e), 319, NPDES,
Clean Lakes, and the National Estuary Program
Coordinate Office of Water grants application and reporting processes to
facilitate financial support for the Watershed Protection Approach
• Reference the delineated basin in which a facility is located or an activity
occurs on all documents (e.g., permits, grants)
Coordinate interstate basin efforts as appropriate
2. NPDES Permits
Implement a methodology for issuing NPDES permits on a watershed basis
(i.e., decisions about point source controls are based on an overall assessment
of environmental priorities and concerns within a basin) by developing a
basin management plan and:
1) synchronize permit issuance within basins, or
2) assure that permits are issued in accordance with the basin
management plan
Emphasize training on the concepts of watershed protection at the local, State
and Federal levels
Emphasize permit development for minors and majors that pose a significant
environmental threat to a basin or watershed
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Streamline the NPDES permit development, issuance, and review process;
implement key permit streamlining recommendations developed in support of
the National Performance Review
Support development of phased TMDLs as part of the permit development
process as information becomes available for stressors of concern hi a
particular basin/sub-basin
Support the development of NPDES permit conditions as the basis for future
pollutant trading, where appropriate:
Develop and implement pollution prevention initiatives to reduce point source
loadings within watersheds
Consider the use of general permits within basins or sub-basins/watersheds
where appropriate
Target high risk basins or sub-basins for storm water industrial pollution
prevention plan reviews and early implementation of more rigorous storm
water permits, as necessary
Coordinate municipal storm water and CSO permits where feasible
Focus pretreatment resources for program development or modification,
technical assistance, local limits development, and compliance actions in
priority basins
Coordinate sludge management and permitting with watershed planning and
implementation activities, where feasible
3. Monitoring and Assessment
• Develop a State-wide monitoring strategy to assure the most effective
targeting of limited monitoring resources and coordinate collection and
analysis of NPDES, nonpoint source, and other watershed data
• Establish point source ambient monitoring requirements where appropriate to
- support assessment of watershed conditions; this action may provide
opportunities for group monitoring plans for multiple discharges to the same
basin
Promote comparable data collection, analysis, and utilization by all
stakeholders (e.g., NPDES, 303(d), 304(1), and 319) through revisions to
information collection and management systems (e.g., permit applications and
compliance monitoring, PCS, TMDL development, 305(b), NEP, STORET,
and water body systems)
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4. Programmatic Measures and Environmental Indicators
• Revise existing national accountability measures to facilitate implementation
of the Watershed Protection Approach
Focus on minors and majors which pose an environmental threat
Revise permit output expectations to facilitate permit synchronization
and development of basin management plans
Allow more flexibility to target inspection resources on high priority
sub-basins
Establish new measures of success that reflect assessment of progress toward
short-term and long-term watershed protection goals (should reflect ptiblic
health concerns where appropriate); these should be realistic and should
include both interim environmental milestones and specific program activities
5.
Public Participation
Utilize existing NPDES public participation process and development of
basin-wide management plans to encourage informed participation by
watershed stakeholders including permittees, environmental groups, and the
general public
Educate dischargers, interest groups, and the public about watershed planning
efforts, including upstream and downstream problems and solutions
Seek broad public participation in identifying local environmental goals for
each basin and request information from dischargers, interest groups, and the
public on problems and historic trends
Enforcement
Within the base national enforcement program, include emphasis on minor
facilities which are discharging to a priority basins
Enforcement activities in priority basins will include compliance
assurance, compliance monitoring, and taking administrative/judicial
actions for non-compliance
Use 308 authorities, inspections and supplemental environmental projects,
where appropriate, to support watershed assessment, planning, and restoration
activities and to promote pollution prevention
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Identify priority categories of unpeimitted dischargers where there is evidence
of potential wide-spread water quality problems in priority basins
Modify the scope and operation of the Permit Compliance System (PCS) to
include minors in priority basins and other data fields required to support
information management within the watershed
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Appendix (Suggested Regional Action Items) to NPDES Watershed Strategy
)
Regional action plans for facilitating State watershed protection approach (WPA)
development must be based on State program assessments. .A separate Regional action plan
should be tailored for each State based on the State's status and needs to support progress
in each of the six Strategy component areas.
The recommended action items listed below are specific tasks that can be included in a
Regional plan. Regions should carefully consider each of these recommendations and
choose those that are most appropriate for a given State or develop others based on the
results of then- State assessments. This State-specific approach will lead to a more rapid
and effective implementation of the Watershed Protection Approach.
The list of recommended Regional action items is organized according to NPDES
Watershed Strategy components, with the addition of a Funding Administration section.
Within each component area, these recommendations are grouped into three categories
which describe the status of State watershed programs: (1) States Without a State-wide
Watershed Protection Approach; (2) States Developing a State-wide Watershed Protection
Approach; and (3) States Implementing a State-wide Watershed Protection Approach.
Action items that are listed in an earlier status category may be appropriate actions for
States with more developed State-wide WPAs, as well.
State-wide Coordination
I
States Without a State-wide WPA:
• Conduct educational workshops for States as well as other stakeholders using
information from other States that have developed and are implementing watershed
protection approaches.
• Meet with the State to identify impediments to implementing a WPA.
• Identify and describe the areas hi which program coordination will enhance water
quality management activities (e.g., development of TMDLs, NPDES permit
issuance efficiency).
i
States Developing a State-wide WPA:
• Provide a forum to States to share information on the development and
implementation of a .WPA (e.g., newsletter, conference calls, conferences).
• Work with States to delineate basin boundaries and establish inter-basin priorities,
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ensuring that wellhead protection and existing Comprehensive State Ground Water
Protection Program (CSGWPPs) priorities are considered in the decision making
process. Where appropriate, utilize existing analysis reflected in the 319, 303(d),
303(e), Clean Lakes, NEP, and NPDES programs.
• Assist States with the identification of stakeholders in basins (NEPs may be of
assistance in coastal areas).
• Assist States with the development of agreements/memoranda of understandings
with other Federal and State agencies for the purpose of supporting the State's
watershed protection approach.
• Provide technical assistance for the development of a State-wide watershed
protection approach framework document; such a document includes a program
description for all participating programs, agencies, and the general public.
• Assist States with the identification and recruitment of other agencies to serve as
partners for the State-wide basin management framework.
• Identify the mechanisms developed to implement the State WPA (e.g., policies,
regulations).
• Describe the process for involving Federal agencies, Indian tribes, and local
governments.
States Implementing a State-wide WPA:
• Conduct reviews of State programs which take into account the scope and schedule
of State's programs and basin plans to the extent possible.
NPDES Permits
States Without a State-wide WPA:
• Work with States to identify the number and types of dischargers in each basin.
• Work with States to sequence basins, ensuring that the permit workload is evenly
distributed hi any given year.
• Work with States on scheduling issues associated with synchronizing permits by
basin, or on issues associated with permit issuance under the basin management
plan.
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• Provide guidance on mechanisms and approaches for modifying individual permits
(e.g., short-term permits, administrative extensions, expedited renewal procedures,
basin general permits).
States Developing a State-wide WPA:
• Assist States in developing a strategy that defines the criteria and approach for
issuing permits consistent with the basin plan.
• Provide technical assistance to States for evaluating and assigning priorities to
permits within a basin. These procedures will help determine the appropriate level
of effort and scrutiny that should be devoted to each permit.
• Support States in assuring that Best Management Practices (BMP) established in
NPDES permits are designed to prevent contamination of the State's priority
ground water. •
States Implementing a State-wide WPA:
• Support the development of automated permitting systems.
• Assist with the development of innovative permits that use the full potential of the
basin-wide approach (e.g., trading, monitoring, pollution prevention and
conservation, basin-wide general permits).
• Expand public notification to include infbrmation on permits in the basin plan.
Monitoring and Assessment
States Without a State-wide WPA:
• Help to develop a State-wide monitoring strategy involving State resources,
discharger monitoring consortiums, and other Federal agencies. Assist with
negotiations for shared monitoring resources.
• Assist with the development of assessment methods (consider biological and
ecological criteria) and record keeping for targeting and ranking water quality
problems. When assessing the status of a watershed, surface water, ground water,
coastal waters, wetlands, sediments, and habitat are all factors that should be
considered. The assessment of the watershed should determine if the waters are
meeting their designated use, and also provide information on critical areas,
endangered species habitats, and areas needing special protection.
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• Identify how NPDES ambient monitoring can be incorporated with other
monitoring efforts.
States Developing a State-wide WPA:
• Permits will contain ambient monitoring requirements as appropriate to support the
basin monitoring plan.
• Support upgrades of information management systems, especially the use of
geographic information analysis systems which facilitate analysis and display of
environmental: information hi a geographic format.
• Help to refine and consolidate the monitoring objectives and reports of the CWA
programs requiring monitoring resources (e.g., 305(b), 303 (e), CSGWPPs) to
promote the targeting and ranking objectives of the watershed approach.
• Work with States to develop a State monitoring strategy that allows regions to
fulfill cross program requirements through a single integrated monitoring system
(e.g., stormwater, 319, TMDL, drinking water.)
States Implementing a State-wide WPA:
• Provide technical assistance to develop improved environmental indicators and
monitoring strategies.
• Provide support for the development of a citizen/volunteer monitoring program
• Participate hi basin water quality assessments and contribute to targeting and
ranking of environmental issues.
• Design pollution prevention and restoration programs relying, where appropriate,
on total maximum daily loads or permits to address impaired ecosystems. Design
monitoring programs to gather additional data to allow program and project design.
Program Measures and Environmental Indicators
States Without a State-wide WPA:
• Identify areas of flexibility with existing program measures.
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States Developing a State-wide WPA:
• Negotiate a consolidated reporting format for the State to satisfy CWA reporting
requirements. i
• Establish tracking measures to monitor implementation schedule for various
components of the Watershed Protection Approach including: delineation and
sequencing of basins, rescheduling of NPDES permits, development of a State-wide
framework document.
• Establish key environmental indicators that will be used by State to measure
progress toward achievement of both CWA and local goals and environmental
objectives.
States Implementing a State-wide WPA:
• Evaluate State basin plans in a manner that is consistent with each State's
watershed framework and also ensure that the plans support the goals and
objectives of the CWA.
• Develop a strategy to use basin plans to implement phased TMDLs in all States.
• Develop an assessment approach for regional oversight that is geographically
targeted which measures the success of watershed protection activities and provides
information to the decision makers when updating basin plans.
• Encourage the development of innovative environmental indicators for each basin.
Public Participation
States Without a State-wide WPA:
• Identify and develop more efficient means of notifying the public.
States Developing a State-wide WPA:
• Promote outreach to educate the public about the NPDES program and the
components of the WPA. Provide trainirjig on the inter-relationship between habitat
protection, ground water contamination, drinking water source protection, nonpoint
source impairment, and the point source program.
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• Work with the State to establish a forum in which the public can help to identify
water quality problems and establish goals for the preservation of high quality
waters.
States Implementing a State-wide WPA:
• Encourage State linkages with local land use planning authorities to facilitate the
use of water quality information hi the planning process (e.g. EPA Region IX
North Bay Initiative).
• Ensure that basin plans are written as educational documents that can be read by
the lay public and which promote environmental stewardship hi the basin.
• Target water quality standards hearings to watersheds.
Enforcement
States Without a State-wide WPA:
• To supplement the current information on major facilities, conduct an inventory of
each priority watershed, as necessary, using traditional enforcement authorities (e.g.
308 letters or inspections) to identify minor facilities which will be required to
have a permit.
States Developing a State-wide WPA:
• Use enforcement to correct violations at facilities which are causing the greatest
degradation of a basin.
• Assist State hi developing a State inspection strategy to support WPA. The
Regions and States should develop criteria to evaluate which facilities should be
inspected hi a given year.
• States Implementing a State-wide WPA:
• For majors and minors hi priority watersheds, focus attention during report reviews
and compliance screening on the completeness of the ambient quality information
submitted by the permittee, as required by the permit.
• Use PCS to track loadings of pollutants in priority watersheds.
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Funding Administration
States Without a State-wide WPA:
• Conduct an assessment of the funding sources. Develop plans to reduce the
"overhead" burden to States in administering grants.
States Developing a State-wide WPA:
• Utilize flexible authorities to support the WPA.
States Implementing a State-wide WPA:
• Determine if basin ranking and priority setting criteria are effectively administered
and allow for focusing the appropriate level of program resources to remediate the
highest risk environmental problems.
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