Watershed  Protection:
             A  Statewide Approach
            Assessment and Watershed Protection Division
             Office of Wetlands, Oceans, and Watersheds
                U.S. Environmental Protection Agency
                       401 M Street, SW
                     Washington, DC  20460
                          August 1995
Cover:  Water quality management units designated by the Washington
       Department of Ecology.
       Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postoonsumer)


                   The Watershed Protection Approach (WPA) is a departure from the
                   way the EPA has traditionally operated its water quality programs and
                   how federal, tribal, and state governments have typically approached
                   natural resource management. Resource management
                   programs —programs for wetlands protection, wastewater discharge
                   permitting, flood control,  farmer assistance,  drinking water  supply,
                   fish and game management, and recreation —have tended to operate
                   as individual entities and occasionally at cross purposes.

                   We now generally recognize that the critical environmental  issues
                   facing society are so intertwined that a comprehensive, ecosystem-
                   based approach is required. We also recognize that solving
                   environmental problems depends increasingly on local governments
                   and local citizens. Thus,  the need to integrate across traditional
                   program areas (e.g., flood control, wastewater, land use) and across
                   levels of government (federal, state, tribal, local) is leading natural
                   resource  management toward a watershed approach.

                   One emerging framework for a statewide Watershed Protection
                   Approach focuses on organizing and managing  by a state's major
                   watersheds, which are called  basins in this document.  In this
                   statewide approach, activities such as water quality monitoring,
                   planning  and permitting are coordinated on a set schedule within large
                   watersheds or basins.  Involvement of other natural resource agencies
                   is actively sought to achieve water quality and ecosystem goals.

                   This document is one of two guides to watershed  protection designed
                   for state  water quality managers.  A second guide, Watershed
                   Protection: A Project Focus, describes another aspect of the
                   Watershed Protection Approach—developing  projects for the
                   individual  watershed.  It provides a blueprint for designing and
                   implementing watershed projects, including references and  case

                   I trust this Watershed Protection Approach document will provide a
                   useful guide for state water quality managers and  others involved in
                   watershed-based activities as they adopt, implement and evaluate
                   watershed protection programs.

                                                      Robert H. Wayland, III,  Director
                                           Office of Wetlands, Oceans and Watersheds
                                                U.S. Environmental Protection Agency

                  This document was prepared by Amy Sosin and Donald Brady of the
                  Assessment and Watershed Protection Division, EPA Office of
                  Wetlands, Oceans, and Watersheds; Trevor Clements and Clayton
                  Creager of The Cadmus Group and Michael McCarthy, Bill Cooler, and
                  Kathleen Mohar of Research Triangle Institute. The authors gratefully
                  acknowledge the comments of reviewers from within EPA and other
                  agencies including the Delaware Department of Natural Resources and
                  Environmental Control,  the North Carolina Division of Environmental
                  Management, and the Metropolitan Washington Council of

                                                             TABLE OF CONTENTS

            Acknowledgements  	      jv
            Figures  	' ' ' '  '      vjj
            Highlights  	      vjij
            Executive Summary	      jx

            The Watershed Protection Approach  	      1_1

            1.1    Historical Perspective 	      1_1
            1.2    The Clean Water Act 	      1-1
            1.3    The Safe Drinking Water Act	      1-2
            1.4    The Watershed Protection Approach (WPA)  	      1-3
            1.5    Managing by Hydrologic as Well as Political Units	      1-7
            1.6    Purpose of This Document and Intended Audience  ....      1-10

            Managing by Watersheds:  Common Elements 	      2-1

            2.1    Management Units	      2-1
            2.2    Management Cycles	      2-6
            2.3    Stakeholder Involvement	      2-9
            2.4    Strategic Monitoring	      2-10
            2.5    Assessment	      2-11
            2.6    Assigning Priorities and Targeting Resources	      2-13
            2.7    Developing Management Strategies	      2-14
            2.8    Management Plans	      2-16
            2.9    Implementation  	      2-18

            Why Manage by Watersheds?	     3-1

            3.1   Water Quality Programs Can Focus More Directly on
                 the Resource 	      3_1
            3.2   The Basis for Management Decisions is Improved  	      3-1
            3.3   Program Efficiency  is Enhanced	      3-2
            3.4   Coordination Among Agencies in the State Can Be
                 Improved	      3.3
            3.5   Resources Are Better Directed to Priority Issues   	      3-3
            3.6   Coordination with EPA Can Be Improved  	      3-5
           3.7   Consistency and  Continuity  Are Encouraged	      3-6
           3.8   Opportunities for Data Sharing Are Enhanced  	      3-6
           3.9   Public Involvement  Is Enhanced	      3-7
           3.10  Innovative Solutions Are Encouraged 	      3-8

                                                             TABLE OF CONTENTS

   4        Getting Started  	      4-1

            4.1    Establishing a Common Direction	      4-1
            4.2    Managing the Transition  	      4-2
            4.3    Documenting the Approach	      4-3
            4.4    Identifying Barriers	      4-5
            4.5    Tailoring the Approach  	      4-6

   5        References  	      5-1

Appendix A:   How Does Ground Water Protection Fit?  	      A-1

Appendix B:   Management Cycle for the State of Nebraska	      B-1

                                                           TABLE OF CONTENTS










Features of the Watershed Protection Approach  	      1-4

Emerging framework for achieving CWA goals  	      1-6

Statewide watershed management and key documents
resulting from the approach  	      1-9

Common elements of a statewide watershed management
approach	      2-2

Hierarchy of nested watersheds	      2-5

Watershed management goals, objectives,  and stakeholder
matrix	      2-17

Major steps in developing and implementing basin water
quality  management plans	      2-20

Example framework document outline  	      4-4

                                                              TABLE OF CONTENTS


 State of Washington's Water Quality Management Areas	     2-4

 North Carolina's Basin Cycle	     2-7

 Washington's Basin Cycle  	     2-9

 Special Stakeholders in Delaware, Idaho, and Texas	     2-10

 Two States' Approaches to Monitoring  	     2-12

 A Watershed Targeting Approach	     2-14

 Goals and Objectives of the Klamath River Basin Restoration Program  	     2-15

 Nutrient Trading in the Tar-Pamlico Basin	     2-16

 Basin Management Plans in Delaware 	     2-19

 Alabama's Use of Its Comprehensive State Ground Water Protection
 Program to Coordinate Its Program  	     3.4

 Regional Flexibility to Accommodate the Transition  	     3-6

 Data Sharing in North Carolina  	     3.7

 Providing Fish Passage	     3.9

 Ecological Restoration as a Cost-effective Solution	     3-10

 Implementing Statewide Approaches in Delaware and Texas	     4-2

 Key Issues Addressed by Delaware in Developing a Basin Management
 Framework	     4.5

 Comprehensive  Source Water Protection in Massachusetts	      4-8

The Role of Basin Plans in Nebraska  	      4-11

                                                             EXECUTIVE SUMMARY
                   The Watershed Protection Approach is a strategy for effectively
                   protecting and restoring aquatic ecosystems and protecting human
                   health. This strategy has as its premise that many water quality and
                   ecosystem problems are best solved at the watershed level rather
                   than at the individual waterbody or discharger level.  The Watershed
                   Protection Approach has four major features:  targeting priority
                   problems, a high  level of stakeholder involvement, integrated
                   solutions that make use of the expertise and authority of multiple
                   agencies, and measuring success through  monitoring and other data

                   One framework that  states use to implement the Watershed
                   Protection Approach  focuses on  organizing and managing by the
                   state's major watersheds, which are called basins in this document.
                   This flexible framework encompasses management and protection of
                   ecosystems and human health at three levels:  the state, the basin,
                   and the watersheds within each basin.  Some issues are best
                   addressed at the watershed level, such  as  controlling nutrient loading
                   to small lakes or restoring headwaters riparian habitat quality.  Other
                   issues may be best addressed at the basin  level, such as phosphate
                   detergent  bans, wetlands mitigation banking, or nutrient trading.  Still
                   other activities and solutions are  best implemented at the state level,
                   including policies on toxics control or the operation of permit

                  To be comprehensive, the approach  requires consideration of all
                  environmental concerns, including needs to protect public health
                   (including drinking water), critical habitats such as wetlands,
                  biological integrity and surface and ground  waters.  This involves
                  improved coordination among federal, state and local agencies so  that
                  all appropriate concerns are represented. Such involvement  is
                  especially important to integrate emerging programs such as ground
                  water protection with older program  frameworks. So, for example,
                  the concerns addressed through  Comprehensive State Ground Water
                  Protection  Programs (CSGWPPs), Wellhead  Protection Programs,
                  National Estuary Programs or State Management Plans for Pesticides
                  would be considered along with concerns addressed by wetlands
                  protection  programs and our more traditional programs for point and
                  nonpoint source pollution prevention and control.  The state

                                                              EXECUTIVE SUMMARY
                   experiences on which this document are based reflect different levels
                   of integration.  Thus, although the document is based on their
                   experiences, it does attempt to identify  opportunities for incorporating
                   a truly comprehensive approach.

                   A number of states, for example, are developing watershed
                   approaches and CSGWPPs tailored to their priorities and individual
                   local conditions.  Together, these approaches will serve as a broad
                   framework for facilitating surface and ground water coordination and,
                   ultimately, will involve all appropriate state agency staff in setting
                   goals, establishing priorities, convening  and overseeing watershed
                   teams and implementing integrated and  effective solutions.

What Does Managing by Watersheds Entail?

                   A statewide watershed  approach, as described  in this document, is an
                   approach to managing water quality by  major hydrologic units.
                   Typically, activities such as monitoring,  planning, and permitting are
                   conducted according to a set schedule (e.g., monitoring in years 1
                   and 2, data analysis and modeling in year  3, plan development in year
                   4, permit issuance and plan approval in  year 5).  Several state
                   approaches have other elements in common as well:

                   •   Management units—Large hydrologic units  (e.g., major river
                       basins or aquifers) are delineated by the state;  each "basin"
                       contains multiple watersheds.

                   •   Management cycles—A state's basins are grouped  in sequence so
                       that the entire state is studied, and  management plans developed,
                       in a set period (typically, 5 years).

                   •   Stakeholder involvement— Agencies, organizations, and
                       individuals  interested in the water quality, ecosystem health, and
                       management strategies are included in watershed management

                   •   Strategic monitoring—Water quality and ecological  health are
                       monitored to measure the extent of  problems and the stressors
                       involved; this is typically done on a  rotating basis (e.g., two
                       summers of sampling every 5 years  for a given basin).

                   •   Assessment— Data analysis and professional judgment are used
                       to identify problems, sources, and stressors; water quality
                       standards are integral to assessments  because  they reflect criteria
                       for restoring and maintaining the physical, chemical, and
                       biological integrity of water.

                                                              EXECUTIVE SUMMARY

                       Prioritization and targeting—Waterbodies or watersheds are
                       ranked according to resource value, degree of impairment, and
                       other factors; specific watersheds or waterbodies are targeted for
                       special management attention.

                       Development of management strategies—Realistic goals are set
                       for the basin and its watersheds; management strategies are then
                       developed before allocating scarce resources.

                       Basin or watershed plans—These plans document the assessment
                       results, goals, and  chosen management strategies for each basin
                       or watershed; a plan may be issued in  conjunction with National
                       Pollutant Discharge Elimination System (NPDES) permits and
                       revised periodically (e.g., every 5 years); the plan also serves to
                       educate the public  on basin-specific issues.

                       Implementation—Selected  management strategies are
                       implemented in the years between updates of the plan.
Why Implement a Watershed Protection Approach?
                   Watershed protection provides states with a framework for protecting
                   their watersheds and addressing all priority problems, not just those
                   most readily solved. States already implementing a Watershed
                   Protection Approach anticipate many benefits, including:

                   •   More direct focus by stakeholders on achieving ecological goals
                       and water quality standards rather than on measurement of
                       program activities such as numbers of permits or samples

                   •   Improved basis for management decisions through consideration
                       of both traditional stressors (e.g., toxics from point sources,
                       biochemical oxygen  demand, nutrients) and nonchemical
                       stressors (e.g., habitat loss, temperature, sediment, low flow)

                   •   Enhanced program efficiency because activities such as
                       monitoring or permit writing are focused on a limited number of
                       watersheds at a time

                   •   Improved coordination  among federal, state and local agencies
                       and other organizations, including increased data sharing and
                       pooling of resources

                   •   Enhanced public involvement, including better relations with
                       permittees due to increased involvement and greater consistency
                       and equitability in permit conditions

                                                              EXECUTIVE SUMMARY
                   •   Innovative solutions such as ecological restoration, wetlands
                       mitigation banking, and market-based solutions (e.g., pollutant
                       trading or restoration in lieu of advanced wastewater treatment).

How Does a State Get Started?

                   Switching from program-centered to watershed management is a
                   major functional change for most state agencies, although it need not
                   involve a change in organizational structure.  Strong commitment of
                   high-level  management is essential, as is strong leadership on the part
                   of the individual(s) appointed to direct implementation.  Important first
                   steps include budgeting sufficient time for key staff who will develop
                   the approach, educating all parties on  the principles of watershed
                   management, and establishing an efficient means of communication
                   among staff. Several states have used outside facilitators to bring
                   staff from various program areas together to agree  on common
                   purposes and work out potential "turf" issues.

                   The lead agency should consider preparing a detailed framework
                   document that describes overall goals  and objectives, the basin cycle,
                   basin-specific schedules, roles and responsibilities of each
                   organizational unit,  procedures for  developing plans, and guidelines
                   for public  involvement.

                   Any Watershed Protection Approach must be tailored to suit the
                   state's particular situation.  State officials can benefit from reviewing
                   the framework documents and, in some cases, watershed
                   management plans from states such as North Carolina, South
                   Carolina, Nebraska, Delaware and Washington.

How Does Ground Water Protection Fit?

                   Ground water and surface water are often directly connected, with
                   water flowing back and forth from one resource to  the other over
                   time.  The quality of ground water contributes to the overall condition
                   of the watershed, and ground water may serve as a medium for
                   transporting pollutants to surface waters (and vice  versa). In many
                   instances, the Watershed Protection Approach is an appropriate
                   framework for integrating surface water and  ground water protection.

                   In other instances, ground water protection presents challenges that
                   differ from those encountered  in protecting surface waters. For
                   example, because ground water is so expensive and difficult to clean
                   up, there is heavy emphasis on prevention. Other dissimilarities
                   between the two resources include differing  transport mechanisms,
                   monitoring approaches and resource boundaries (e.g., aquifer
                   boundaries may not coincide with basin or watershed boundaries).

                                           EXECUTIVE SUMMARY
A truly comprehensive statewide approach, therefore, must be
designed to address specific concerns about ground water in addition
to concerns about surface water.  These concerns include  how to
address immediate and ongoing ground water program priorities such
as wellhead protection with a state's Watershed Protection Approach.
CSGWPPs provide states with the opportunity to implement an
aquifer protection approach that integrates well with a Watershed
Protection Approach.  CSGWPPs incorporate the principles of the
Watershed Protection Approach in that they are place-based, include
the relevant stakeholders, consider multiple environmental  objectives
and give the leading role to states.  CSGWPPs play an important part
in tailoring all water programs to meet specific needs within
watersheds at the local, state and federal levels.


                                      1. THE WATERSHED PROTECTION APPROACH


1.1 Historical Perspective
                   The concept of water resources management within watersheds
                   originated as early as the 1890s with the work of the U.S. Inland
                   Waterways Commission.  The Commission, with the backing of
                   President Roosevelt, reported to Congress in 1908 that each river
                   system— from its headwaters in the mountains to its mouth at the
                   coast —is an integrated  system and  must be treated as such (Inland
                   Waterways Commission,  1908). The focus of water resources
                   management then and throughout the first half of the century was on
                   efficient  use of water resources for  such purposes as energy
                   production, navigation,  flood control, irrigation, and drinking water.

                   The 1950s and 1960s saw increased emphasis on improving ambient
                   water quality and protecting the Nation's drinking water, much of
                   which comes from ground water. The Federal Water Pollution Control
                   Act of 1956 provided large-scale funding of publicly owned treatment
                   works. The Water Quality Act of 1965 required states to develop
                   water quality standards for interstate waters.  River basin compacts
                   were formed to protect major systems such as the Delaware and
                   Colorado Rivers. Some state sanitation commissions  adopted a river
                   basin approach to their  work.  They developed basin plans that
                   classified individual waterbodies according to  their best uses. These
                   early water quality managers walked, boated,  and drove throughout
                   entire river basins, documenting outfall pipes and collecting ambient
1.2  The Clean Water Act
                   In 1972, the Federal Water Pollution Control Act Amendments (PL92-
                   500) established as a national goal the restoration and maintenance of
                   the physical, chemical, and biological integrity of  the Nation's waters.
                   The dominant features of this Clean Water Act (CWA) were a Federal
                   permitting program (the National Pollutant Discharge Elimination
                   System or NPDES) and massive funding for wastewater treatment and
                   state water quality programs.  Under NPDES, each discharger receives

                                      1.  THE WATERSHED PROTECTION APPROACH
                   a permit containing numerical effluent limits that are, at a minimum,
                   based on best available wastewater treatment technology or other
                   guidelines (technology-based limits); more stringent limits are issued
                   where needed to take into account the condition of the waterbody
                   (water quality-based limits).

                   Under Section 303(e) of the CWA, states prepared basin plans for
                   controlling their point source problems.  These plans consolidated
                   most known information about dischargers and  water quality and
                   helped form the basis for grant decisions for wastewater treatment.
                   Mathematical models were used to determine allowable loads from
                   municipal and industrial treatment plants.  However, after the initial
                   plans were completed, most states maintained only a limited basin
                   planning function while focusing on individual point source problems.

                   The CWA also set the stage of early ground water protection efforts.
                   Under Section 102, EPA, states and other federal and interstate
                   agencies are authorized to develop comprehensive programs to
                   reduce, prevent and eliminate pollution to ground  water and surface
                   waters.  This authority, and the Resource Conservation and Recovery
                   Act, the Federal Insecticide, Fungicide, and Rodenticide Act and other
                   laws provided for the initiation of Comprehensive  State Ground Water
                   Protection Programs (CSGWPPs).

                   In the 1987 amendments to the  CWA, Congress required  states to
                   expand their programs for dealing with toxicants,  nonpoint sources
                   (NPSs), wetlands, water quality standards and other topics. These
                   requirements have strained state budgets and made  multi-agency
                   programs such as NPS management more difficult to coordinate
                   effectively. Moreover, the states' progress in eliminating  point source
                   pollution  has revealed that NPS pollution and  habitat degradation
                   account for most of the Nation's remaining water quality problems
                   (U.S. Environmental  Protection Agency [EPA], 1994a).

1.3  The Safe Drinking Water Act

                   The 1974 Safe Drinking Water Act (SDWA) drew together several
                   important programs protecting public health that now need to be
                   considered within a comprehensive  Watershed Protection Approach.
                   Then, in the late 1970's, hazardous waste sites were found to be
                   affecting public  water systems.  Some of these sites suffered from
                   surface water intrusion  and contaminated ground  water discharge.
                   The 1986 amendments established  further the basis for protecting
                   ground water supplying drinking water to public water systems and
                   private users. The types of contaminants that must be removed by
                   drinking water systems was quadrupled.  The requirements for

                                       1. THE WATERSHED PROTECTION APPROACH
                   testing this expanded list of contaminants impose significant costs on
                   State and local drinking water monitoring programs.

                   EPA has also established  the Source Water Protection and Wellhead
                   Protection Programs under the  SDWA.  Source Water Protection
                   emphasizes preventing contamination of drinking water resources and
                   includes wellhead protection and sole source aquifer watershed
                   control plans.  The Wellhead Protection Program sets priority on
                   contamination to ground  waters that will provide drinking water in the
                   next 5 to 20 years. It relies upon hydrologic  models of ground  water
                   flow to define the protection area which may include the portion of
                   the stream and the watershed upstream from the well. The Sole
                   Source Aquifer Program allows the  public to define entire aquifers that
                   provide at least half the population's drinking water, whether for
                   public or private use. Watershed control plans under the surface
                   water treatment rule are used to define the area providing drinking
                   water to a public water system experiencing  microbial contamination.
                   The area is to  be managed to reduce or eliminate contaminant

1.4  The Watershed  Protection Approach (WPA)

                   A comprehensive approach to water resource management is needed
                   to address the myriad water quality problems that exist today from
                   nonpoint and point sources as well  as from habitat degradation.  The
                   WPA is a management approach  for more effectively protecting and
                   restoring aquatic ecosystems and protecting  human  health. The EPA
                   Office of Water is using this approach to focus on hydrologically
                   defined resource areas—watersheds and aquifers.  The WPA
                   recognizes that water quality management must embrace human and
                   ecosystem health and that managing for one without considering the
                   other can be detrimental to both. The WPA allows managing a range
                   of inputs for specific outputs.  It emphasizes  all aspects of water
                   quality including chemical water quality (e.g., toxicants and
                   conventional pollutants),  physical water quality (e.g., temperature,
                   flow, circulation, ground and surface water interaction), habitat
                   quality (e.g., channel morphology, substrate composition, and riparian
                   zone characteristics), biological health  and biodiversity (e.g., species
                   abundance, diversity, and range)  and subsurface bio-geochemistry.

                   The WPA has four  major features: targeting  priority  problems,
                   stakeholder involvement,  integrated  solutions, and measuring success
                   (Figure 1-1).  It is important to  note that the WPA is  not a new
                   program that competes with or replaces existing water quality
                   programs; rather, it is a framework within which ongoing programs
                   can be integrated effectively.  Further, a watershed approach can

                                                                1.   THE WATERSHED PROTECTION APPROACH
                                                         Targeting Priority

                                                        All significant problems in a
                                                        watershed are Identified and
                                                        addressed, not just the
                                                        problems that are familiar or
                                                        easily solved. Monitoring
                                                        provides critical data for this
                                            Problems that may pose health
                                            or ecological risks in a watershed

                                            Industrial wastewater discharges
                                            Municipal wastewater. stormwater,
                                              and combined sewer overflows
                                            Waste dumping and injection
                                            Nonpoint source runoff or seepage
                                            Atmospheric deposition
                                            Habitat alteration, wetlands loss
                                            Hydrologic modification
      Stakeholders include

      State environmental, public health.
       agricultural, and resource agencies
      Local/regional boards, commissions,
       and agencies
      EPA water and other programs
      Other Federal agencies
      Indian tribes
      Public representatives
      Private wildlife and conservation
      Industry sector representatives
      Water suppliers
      Academic community

Working as a task force,
stakeholders reach
agreement on goals and
approaches for addressing a
watershed's problems, the
specific actions to be taken.
and how they will be
coordinated and evaluated.

The selected tools are
applied to the watershed's
problems, according to the
plans and roles established
through stakeholder
Coordinated action may be taken
In such i
Voluntary source reduction
  (e.g.. waste minimization, BMPs)
Permit issuance and enforcement
Standard setting
Direct financing and incentives
Education and technical assistance
Critical area protection
Ecological restoration
Remediation of contaminated soil
Emergency response to leaks or spills
Effectiveness monitoring

                                                         Early in the project, stake-
                                                         holders agree on ecological
                                                         and administrative indicators
                                                         that will demonstrate
                                                         progress. These measures
                                                         are tracked throughout the
                                                         project by water quality
                                                         monitoring and other types
                                                         of data gathering.
                        Figure 1-1.   Features of the Watershed  Protection Approach


 provide benefits to individual citizens and the public and private

 Individual citizens benefit because watershed protection  improves the
 environment.  The public sector benefits because agencies can
 accomplish more through cooperation with other stakeholders than
 they can on their own with limited resources.  The participation of
 local organizations ensures that those who are likely to be most
 familiar with a watershed, its problems, and possible solutions play a
 major part,  often a leadership role.  The private sector can benefit
 because the burden of water resource protection is distributed more
 equitably among pollution sources.  All stakeholders benefit because
 they can participate in decisionmaking that is based on a
 comprehensive assessment of the watershed including all interacting

 The features of the WPA shown in Figure 1-1 include a strong
 monitoring and evaluation component.  Using monitoring data,
 stakeholders identify  stressors that  may pose health and  ecological
 risk in the watershed  and any related aquifers, and prioritize these
 stressors.  Monitoring is also essential to determining the
 effectiveness  of management options chosen by stakeholders to
 address high-priority stressors.  Because  many watershed protection
 activities require long-term  commitments from stakeholders,
 stakeholders need to  know whether their efforts are achieving real
 improvements in water quality.

 Figure 1 -2 illustrates how the WPA fits into the context of CWA
 implementation by a state water quality agency.  The peak of the
 pyramid represents the goal of restoring and maintaining ecosystem
 integrity for human and aquatic health. Water quality standards and
 other environmental objectives are the measures of ecosystem
 integrity that comprise the next level of the pyramid.  As  suggested
 by its position in the pyramid, one purpose of the WPA is to integrate
 the many individual programs that have evolved to implement the
 goals of the CWA (e.g., to restore, protect and maintain the physical,
 chemical and biological integrity  of the Nation's waters) and the
 SDWA (e.g., to protect human health through source water

 CWA Section 303(d) and the Total Maximum Daily Load (TMDL)
 process provide one key legislative and technical underpinning  for the
WPA.  A TMDL may involve all of the actions or programs
shown —point  and  nonpoint source controls, monitoring, and
restoration.  Similarly, SDWA programs for Source Water  Protection
and Wellhead Protection can be key components of the WPA.  Each
state may make more  or less use of  each  of these CWA and SDWA

                                             1.  THE WATERSHED PROTECTION APPROACH
                                         Human Health
                                          and Aquatic
                                       Ecosystem Integrity:
                                     Water Quality Standards
                                    Drinking Water Standards
                                      Watershed Protection
                                                  Within Other Agencies/
                                                    Section 404 Program
                                                    CZMA Program
                                                    USDA Initiatives
                                                    USDOI Initiatives
                                                    Private sector projects
                                                    (e.g., by The Nature
Within the State Water Quality
and Health Agencies
• Point source controls
• NPS controls
• Restoration
• Monitoring
• Enforcement
• Grants
• Incentives
• Drinking water protection
• Ground water protection
• Source water protection
                          Figure 1-2. Emerging framework for achieving CWA goals.

                                       1.  THE WATERSHED PROTECTION APPROACH
                   programs, tailoring them to create its unique watershed approach.
                   Various sources of funding may be brought to bear to carry out the
                   WPA (e.g., federal grants, state appropriations, and permit fees).

                   The pyramid includes initiatives by other agencies as integral
                   components of a WPA.  Examples within the U.S. Department of
                   Agriculture include the Natural Resources Conservation  Service
                   (NRCS; formerly the  Soil Conservation Service or SCS) Small
                   Watersheds Program; another NRCS initiative to delineate consistent
                   watersheds nationwide; and the U.S. Forest Service's South Fork
                   Salmon River Project, where restoration efforts seek to mitigate
                   sediment impacts from past livestock grazing, logging,  and road
                   building activities.

                   The WPA has evolved over the past several years.  In 1991, EPA
                   produced an initial framework document that discussed EPA's
                   concept for watershed protection and outlined EPA's potential role in
                   watershed  protection efforts (U.S. EPA, 1991).  Since that time, EPA
                   has provided support to states and other entities to help build on the
                   many existing regional, state, and local watershed-based programs
                   and watershed projects. Following extensive consultation with the
                   States, EPA issued its National Guidance for Comprehensive State
                   Ground Water Protection Programs (U.S. EPA, 1993a).  EPA has
                   worked with many other Federal agencies to harmonize  the WPA with
                   other agency approaches.  EPA has jointly  and singly sponsored
                   numerous conferences on  watershed management.

                   Point source controls and other traditional approaches to water quality
                   management have  been effective to date in resolving many of our
                   Nation's water quality problems.  The WPA provides a flexible model
                   for tackling the  complex environmental problems that we still face
                   today. In addition, the growing number of water resource programs
                   with overlapping functions requires the coordination and integration
                   that a watershed approach can provide.  A watershed approach also
                   allows new partnerships to form among federal,  state, and local
                   agencies, citizens, and the private sector that are focused on  a
                   specific resource. Finally, the WPA's emphasis on stakeholder
                   participation fosters a sense of ownership and stewardship of local
1.5  Managing by Hydrologic as Well as Political Units
                   Watershed boundaries seldom if ever coincide with jurisdictional
                   boundaries such as state, county or town lines.  Like watersheds,
                   aquifers too are natural hydrologic units that seldom match
                   jurisdictional boundaries but have unique management needs.  This
                   has long presented a special challenge to local and state water

                                      1. THE WATERSHED PROTECTION APPROACH
                   resource managers whose geographic areas of responsibility are
                   politically rather than hydrologically based. It further complicates
                   matters that watersheds occur on a range of scales from the sub-
                   national or regional (e.g., the Mississippi watershed) down to local
                   scale (e.g., the watershed of a small creek). At any scale,
                   watersheds and aquifers function as natural systems within which
                   resource managers and stakeholders can work to establish and
                   maintain the best possible combination of ecological condition and
                   human health and welfare.

                   It is possible to organize watershed management around watersheds
                   at scales large or small. In an average state, there may be ten or
                   more major watersheds containing several hundred moderately-sized
                   watersheds, and thousands of still smaller watersheds within these.
                   Given the variety of scales and geographic units available, then, how
                   can state resource managers best implement their programs on
                   watershed management units?

                   One framework that states use to implement the WPA focuses on
                   organizing and managing by the  state's major watersheds, which are
                   frequently called basins in this document.  This flexible framework
                   encompasses management and protection of ecosystems and human
                   health at three levels: the state,  the basin, and the watersheds (and
                   aquifers) within each basin. Some issues, such as controlling nutrient
                   loading to small lakes or restoring headwaters riparian habitat quality,
                   are best addressed at the local watershed level.  Other issues may be
                   best addressed at the basin level, such as phosphate detergent bans,
                   wetlands  mitigation  banking, or  nutrient trading. Still other activities
                   and solutions are best implemented at the state level,  including
                   policies on toxics control or the  operation  of permit programs.

                   Typically, the state's basins and selected major aquifers become the
                   primary management units in this framework.  Program activities such
                   as permitting, monitoring, modeling, and water quality planning  are
                   scheduled for each basin on a rotating five-year cycle  covering all the
                   state's basins. Other activities such as compliance and enforcement
                   are ongoing throughout the cycle. Products include an initial state
                   framework document describing this approach and individual basin
                   management plans that are updated every five-year cycle (Figure 1-3).

                   When states manage by basins,  their programs are organized around a
                   limited and manageable number  of major watersheds occurring within
                   the state.  Basin-level activities can be coordinated more broadly with
                   statewide actions and policies, or more locally with watersheds  of
                   concern within a basin. This approach can be an improvement on
                   past approaches to water resources management because it compels
                   managers to focus on systems (basins, watersheds and aquifers),

                         1. THE WATERSHED PROTECTION APPROACH
      Watershed  Protection
  State Framework

 A reference document
 that describes how
 statewide manage-
 ment will function for
 a given state*
* Could include a Comprehensive
 State Ground Water Protection
  Statewide Watershed
  Management Approach

A method for integrating
and coordinating watershed
protection throughout a state
    Management Plans

  Reference documents
  that present assess-
  ment results, specific
  management strategies,
  and corresponding
  stakeholder roles for
       Figure 1-3. Statewide watershed management and key
           documents resulting from the approach.

                                      1.  THE WATERSHED PROTECTION APPROACH
                   how well these systems are working, and how the management
                   needs for these systems differ from watershed to watershed.

1.6  Purpose of This Document and Intended Audience

                   This guide  is about the process of establishing a statewide WPA.  It is
                   not technical guidance and does not cover topics such as monitoring
                   or permitting issues in detail.  Rather, it presents common themes or
                   elements among states that have adopted or begun the transition to
                   watershed  management—states such as Delaware, Idaho, Nebraska,
                   North  Carolina, South Carolina, Texas, and Washington. Chapter 2
                   describes these common  elements. Chapter 3 addresses the benefits
                   of statewide watershed management, and Chapter 4 discusses how a
                   state can begin to implement this approach.   Chapter 5 lists
                   references. Additional information about how ground water
                   protection  fits into the approach is presented in Appendix A, and
                   Appendix B focuses on Nebraska's basin cycle.

                   This document is intended for state water resource managers and
                   technical personnel as well as for the natural resource managers in
                   other state, federal, tribal and local agencies with whom they
                   cooperate.   By outlining the components of a statewide approach and
                   by providing examples of how some states are currently operating
                   under  such an approach,  the document encourages the adoption  of
                   watershed-based water quality management by other states.

                   A companion report,  Watershed Protection:  A Project Focus
                   (U.S. EPA,  1995), describes key elements of local-scale watershed
                   projects. Larger watersheds or basins can provide the framework for
                   coordinating multiple watershed projects around the state, for
                   targeting resources, and for operating permit and monitoring
                   programs.  At the same time,  other water quality and ecosystem
                   protection  activities can be managed best at the watershed level.
                   Examples include controlling point and nonpoint  source pollutant
                   loadings to a lake or to a  stream recharging an aquifer and restoring
                   riparian habitat in the headwaters of a watershed.

                             2.  MANAGING BY WATERSHEDS: COMMON ELEMENTS

                  States independently develop watershed approaches to fit their unique
                  circumstances.  Several key elements have emerged, however, that
                  are common in the approaches developed by states to date
                  (Figure 2-1):

                      Management units
                      Management cycles
                      Stakeholder involvement
                      Strategic monitoring
                      Prioritization and targeting
                      Development of management strategies
                      Management plans
                      Implementation of the plans.

                  These are common elements rather than steps; they do not
                  necessarily occur in a sequence.  Stakeholder involvement, for
                  example, is crucial throughout implementation of any watershed
                  approach. The following sections describe each of the common
                  elements in more detail.

2.1  Management Units

                  Management units are the geographic units within which the state will
                  implement its Watershed Protection Approach.  States often select
                  major watersheds or basins as their management units, although
                  aquifers, groups of watersheds,  or composites of ground water and
                  surface watersheds are also used.

                  The U.S. Geological Survey (USGS) has designed and mapped a
                  national system of hydrologic units for  cataloging, sometimes called
                  HUCs, that provide a common national framework for delineating
                  watersheds and their boundaries at a number of different geographic
                  scales. The hierarchical system's largest units, called water resources
                  regions, are each designated by a 2-digit code. Each regional unit
                  may be subdivided into 4-digit subregions, and further subdivided

                           2. MANAGING BY WATERSHEDS: COMMON ELEMENTS
                Implementation /stakeholder
                                                Priorities and
    Figure 2-1. Common elements of a statewide watershed management approach.

into 6-digit and 8-digit units representing smaller and smaller
watersheds. The 8-digit units, which are still fairly large watersheds
averaging thousands of square miles each, are the most detailed
delineations currently available nationwide as a geographic information
system (CIS) coverage or a map.  The approach has been carried
further in individual states down to the 11-digit  and the 14-digit level
to delineate watersheds averaging approximately 100 square miles
and 30 square miles each, respectively. As hydrologic units will be an
important GIS data set within the envisioned National Spatial Data
Infrastructure, all watershed programs wishing to delineate smaller-
scale watersheds should collaborate with this existing national
framework for watershed delineation.

The North Carolina Division of Environmental Management uses river
basin boundaries developed in the 1970s under  CWA Section 303(e).
The state is divided into 17 basins.  The South Carolina Bureau of
Water Pollution Control took a different approach by combining basins
to form five very large basin management units. The highlight on
page 2-4 describes water quality  management areas used for basin
planning  by the Washington Department of Ecology. Many states
have also delineated smaller watersheds for water quality
management.  For example, Virginia has delineated approximately 500
watersheds based on NRCS (formerly SCS) delineations; South
Carolina and Wisconsin have delineated approximately 270 and 330
watersheds, respectively.

Figure  2-2 shows a "nested" hierarchy of watersheds, including a
river basin, USGS Cataloging Units, and NRCS "14-digit watersheds."
NRCS has begun a nationwide initiative to delineate 14-digit
watersheds for natural resource management.  These small
watersheds are subsets of both the USGS Cataloging Units and
previous SCS-delineated watersheds. North Carolina, for example,
has approximately  1,640 14-digit watersheds statewide; they
average 30 square miles in size.

The development of fully compatible watershed boundaries typically
involves close coordination among USGS, NRCS, and state water
quality, coastal management, and GIS agencies, among  others.
Nested watersheds are important because they offer stakeholders
different levels at which to manage water quality.  Basins allow the
state to allocate resources, while small watersheds are useful for local
governments and local NRCS conservation programs.  The nested
watershed approach also facilitates information exchange among all
levels of government, especially  if stakeholders are maintaining data in
a GIS format.

                                     2. MANAGING BY BASINS: COMMON ELEMENTS
 State of Washington's Water dually Management Areas

 The Washington Department of Ecology has divided the State into 23 water quality
 management areas. These areas are groupings of several water resource inventory
 areas (WRIAs) established to respond to the State Water Resources Act of 1971 and
 as sewage drainage basins to respond to the State Water Pollution Control Act. The
 criteria used lay the Department of Ecology for aggregating the WRIAs Into basin
 planning units are

         Common receiving waters and aquifers, where known
         Complexity of the system and pollution sources   .
         Staff resources available
         Regional office boundaries
         Water availability and water-short  areas
         Water use, Including groundwater  supply
         Areas of population growth (actual and potential)
         Loading from septic systems end sewers
         Ratio of unperrmtted to permitted activities
         Water quality condition.
           Western Olympic!
                           •\ South
                           Puget Sound / Upper Yakima
                          Columbia Gorge ^HorseheaverVKitckita
                                                     	 Water Quality Management
                                                         Area boundary
                                                     	 Water Resource Inventory
                                                         Area (WRIA) boundary






                              2. MANAGING BY WATERSHEDS: COMMON ELEMENTS
                   Ecoregions represent another important type of boundary and are
                   useful integrators for managing water quality.  Ecoregions are areas
                   having physical and biological traits that tend to support characteristic
                   aquatic communities.  Ecoregions do not generally coincide with
                   basins or watersheds, and a given basin may cross more than one
                   ecoregion.  However, the two concepts (basin and ecoregion) are fully
                   compatible. For example, basin goals might be based on  biological
                   criteria for each ecoregion that crosses the basin.

2.2  Management Cycles

                   Water quality management activities for each major watershed or
                   basin are completed within a management cycle.  A management
                   cycle has three features that create an orderly system for continually
                   focusing and coordinating management activities to meet water
                   quality standards and other environmental goals:

                   •  A specified time period — Key surface and ground water
                      management activities within a basin (e.g., monitoring,
                      assessment, priority setting, management strategy development,
                      plan preparation, and plan implementation)  occur within a specified
                      time period. The length of the cycle is state-specific,  but most
                      states are using a 5-year cycle to coincide with NPDES permitting

                   •  A sequence for addressing basins — A sequence is established to
                      balance workload from year to year. States find it impractical and
                      inefficient to perform all management activities in every basin at
                      the same time. Therefore, in one year a state may focus on
                      monitoring in one-fifth of its basins; assessment and priority
                      setting in another one-fifth; modeling and TMDL development in
                      another one-fifth; developing management plans in another one-
                      fifth; and implementing management plans in the remaining one-
                      fifth of the state's basins.  In succeeding years of the cycle,
                      efforts rotate among the basin groups.  It takes time to work into
                      this cycle, so the state must determine the sequence in which
                      basins will be  addressed (see the North Carolina highlight on
                      pages 2-7 and 2-8).

                      In choosing a sequence, most states take into consideration the
                      workload requirements as well as the degree of water quality
                      impairment or environmental risk.  Other considerations include
                      data availability and stakeholder support.  See the Washington
                      highlight on page 2-9 for a description of the factors that state
                      considered in establishing its sequence.

                                                     BY BASINS:  COMMON ELEMENTS

North Carolina's Basin Cycle

t^fZZ?^*"***. "*"" ««• 5-vear planning cycle of
next cycte of activfties for that basin wiH be completed in April  1998  Sties to
    Data collection
    Data analysis and modeling
    Basinwide management plan development
    Review and approval of plan and NPDES permits
        Punch Brawl
                                                        Time Fraryig

                                                        Years 1 - 3
                                                        Years 1 - 4
                                                        Year 4
                           Permitting SolMdul. for North CMta.-. 17 M*r RhMrBMln.

                              2. MANAGING BY WATERSHEDS: COMMON ELEMENTS
 North Carolina's Basin Cycle (continued)

 North Carolina's basin approach includes an emphasis on protection of surface water
 sources of drinking water, in addition to the 17 major river basins, the Department of
 Environment, Health, and Natural Resources has identified over 200 smaller watersheds
 supplying drinking water to communities, These water supply watersheds range in size
 from 3 to 300 square mites and cover about 23 percent of the state.  Local
 governments are required to  develop and implement watershed plans protective of
 drinking water. These plans  address allowable density and types of development in
 these watersheds or portions of watersheds.

 North Carolina's basin approach thus assesses water supply protection needs along with
 other factors and identifies priorities for further protection throughout the basins. Other
 factors considered In setting  priorities for action include ambient water quality, fish
 tissue contamination, nonpoint source impacts, NPDES permits, and storm water
                   •   A schedule for management activities — Once the statewide
                       sequence is established, a detailed schedule of management
                       activities is developed. The schedule specifies when particular
                       activities will occur during the 5-year cycle, thus providing a long-
                       term reference for all stakeholders.  Appendix B contains the
                       detailed schedule for basins in Nebraska; the first 5-year cycle
                       shows how activities will be phased in across the state, and  the
                       second 5-year cycle indicates how activities ultimately will be
                       coordinated across the state.

                   In many states, the management cycle will have to take into account
                   the goals, objectives and activities of a broad range of programs,
                   agencies and public interest groups who  may also be stakeholders and
                   basin team participants.  For example, Delaware will incorporate other
                   natural resource (e.g., fish and wildlife) and county planning agencies.
                   A management cycle for states that take an integrated resource
                   management approach may have different activities, structure, and
                   timing than those that focus exclusively on water quality.  For
                   example, Idaho's Department of Environmental Quality will host
                   workshops to build basin teams from public resource management
                   agencies, interested citizens and tribes.  Each team will determine the
                   cycle for its planning basin.

                   Most of the examples provided in this document focus on  programs of
                   state water quality agencies. However, urban planning and zoning
                   (county planning agencies), habitat restoration and species protection
                   plans (fish and wildlife agencies), and soil conservation and animal

                               21_MANAGING BY WATERSHEDS:  COMMON ELEMENTS
   Washington's Baste Cycle
  By ma, the Washington Department of Ecology will be planning collect™ data
  analysing data, managing information, and Issuing permits for atLst S
  agement units per year. Baseline program activities such as enforcement and
  compliance will continue on a statewide basis.  The Departmeruse^the folfowin*
  factors to establish the schedule of activities in each basin™nage^

         Number of dischargers and permit workload
         CWA Section 3Q3(dHtsted waters
         Completed TMDLs
         Availability of ambient monitoring data
         Threats to beneficial uses {e.g., population growth)
         Likelihood of stakeholder support
         Historical water quality initiatives (e.g., NFS projects)
         Existing and potential funding including grants
         Workload balance.
                   waste management (agricultural agencies) can all contribute to the
                   preservation and protection of waterbody integrity.
2.3  Stakeholder Involvement
                   A  watershed approach creates opportunities for a broad range of
                   stakeholders to play meaningful roles in basin plan development and
                   implementation.  Success depends on the pooled resources, energy
                   and regulatory authority of multiple stakeholders. Stakeholders are all
                   agencies, organizations and individuals that could be affected by
                   water quality management decisions.  They may include:

                      The state water quality agency
                      State agriculture, forestry, and wildlife agencies
                      State public health agencies
                      Municipal and industrial dischargers
                      City and county governments
                      Trade associations
                      Environmental groups
                      Chambers of Commerce
                      Local offices of Federal agencies
                      EPA Regions.

                              2.  MANAGING BY WATERSHEDS:  COMMON ELEMENTS
 Special Stakeholders in Delaware, Idaho, and Texas

 fn Delaware, basin management teams include county planning authorities. Their
 participation allows the Department of Natural Resources and Environmental Control to
 more effectively deat with land use issues that impact physical habitat and to better
 coordinate their local management activities.

 The Idaho Department of Environmental Quality and U,S, EPA Region 10 are jointly
 developing a basin approach for Idaho, Much of Idaho's land is federally owned and
 managed by resource agencies such as the Bureau of Land Management and the Forest
 Service,  A key objective for Idaho is to engage these resource agencies directly in the

 The Texas Natural Resource Conservation Commission is incorporating their Water
 Utilities and Water Resources  {water rights} Programs into their basin framework. These
 types of stakeholders, often neglected by  traditional water quality programs, add
 valuable insight and experience.  For example, the Water Utilities Program has
 established goals to reduce pollutant loading to protect drinking water supplies that are
 consistent with water quality  agency goals. The Water Resources Program brings
 issues such as the timing and  level of diversions into the basin management arena.
                   Stakeholder roles and responsibilities should be defined for each stage
                   of the management cycle.  These roles and responsibilities can

                      Data and research sharing
                      Joint monitoring
                      Identification of waterbody stressors
                      Priority setting
                      Public meetings for goal setting
                      Public outreach events such as presentations or festivals
                      Reviewing management plans
                      Shared commitment of  resources for plan implementation.

                   The highlight above describes efforts by three states to include key
                   stakeholders. The companion volume to this document,  Watershed
                   Protection: A Project Focus (U.S. EPA, 1995), also contains examples
                   of stakeholder involvement.
2.4  Strategic Monitoring
                   Most types of monitoring are strategically coordinated by basin to
                   address various needs such as:

2.5  Assessment
                                  - MANAGING BY W.T»gueDS; COMMOM P. CM».~

                      •  Identifying stressors and their sources

                      •  Determining water quality status and trends

                      •  Targeting priority waterbodies/watersheds for action

                      •  Evaluating the effectiveness of management actions

                      "   ESS" m°delS l° SUPPOrt ™DL "'-"P-nt and permit



                             2.  MANAGING BY WATERSHEDS:  COMMON ELEMENTS
 Two States' Approaches to Monitoring

 The Washington Department of Ecology has revised its monitoring activities, "Core"
 fixed stations throughout the state are sampled monthly every year of the 5-year cycle
 for basic physical and chemical parameters; targeted watershed stations are sampled
 monthly for 1  year in a S-year cycle; biological samples {e.g., benthic
 macroinvertebrates, phytoplankton, fish) are collected mid-summer in year 3; and lakes
 are sampled twice annually, near the start and end of the growing season.  Compliance
 monitoring occurs in years two or three  in the cycle for a given watershed.  Intensive
 surveys are initiated in year two and are completed in years three or four.

 The South Carolina Bureau of Water Pollution Control has also revised its monitoring
 program. The Bureau will continue its statewide primary network of over 200 sites on
 major rivers and estuaries. However,  its secondary network now focuses almost
 entirely on watersheds in one basin per year, with emphasis on

   «   Waterfcodies listed under CWA  Sections 303(d), 304(1), and 314
   •   Watersheds with limited water  quality data
   *   Known point source and NPS problem areas
   •   Waterbodies impacted by groundwater
   •   Waterbodies needing wasteload allocations.
                   years under CWA Section 305(b).  Assessment typically involves
                   comparing monitoring data to state water quality standards to
                   determine whether each waterbody's designated uses (e.g., aquatic
                   life, swimming, drinking) are being achieved. Statistical analyses also
                   may be done to determine whether water quality is improving or
                   declining over time.  Thus, assessments are important because they
                   provide the basis for evaluating the success of past management
                   actions and targeting future management efforts.

                   In recent years, state 305(b) assessments have focused on biological
                   measures of ecosystem integrity in addition to  chemical measures.
                   For example, biological assessments of streams may include measures
                   of fish and benthic macroinvertebrate assemblages and  habitat
                   quality.  This focus on aquatic ecosystem integrity is consistent  with
                   watershed protection approaches and, in fact,  a state may choose to
                   set the water quality goals for a basin or its watersheds in terms of
                   biological integrity.  If a state has developed biological criteria, these
                   can be used to develop water quality goals for individual basins. One
                   basin may have a set of biocriteria for each ecoregion that crosses
                   basin boundaries.

                   stakeholders. MateTc^les  «   assessments -"ore accessible to
                   basin and watershed aoa^a'htS h<5'P determin* whether
                   options chosen in an SSr eye*.'"9
2.6  Assigning Priorities and Targeting Resources
                                                                            - •
                           from the prioritization step above
                    Availability of staff and financial resources


                              2. MANAGING BY WATERSHEDS: COMMON ELEMENTS
 A Watershed Targeting Approach

 tn the late 1980$, the Oklahoma Conservation Commission delineated approximately
 300 watersheds for NFS assessment.  The agency used a numeric index method for
 ranking these watersheds based on waterbody-tevei information. For each watershed
 with adequate data, three factors were calculated:

     •   Beneficial Use factor. Each assessed waterbody received a score according to
        degree of use support from the EPA Waterbody System database. Scores range
        from low (1) for a futly supporting waterbody to high (4) for a nonsupporting
        waterbody*  Weights were assigned based on waterbody size,

     *   Human Use Factor,  Highly populated watersheds and those containing ma|or
        recreational attractions received higher scores {e.g., 4 on a scale from 1 to 4}.

     *   J-ffgh-Quatity/Monctegradatron Factor  This factor was scored according to
        ecological value of assessed water-bodies. Scores range from low (1) for habitat-
        limited fisheries to high (4} for outstanding resource waters.  Scores were
        weighted by waterbody size.

 For more detailed information on this and other state indexes, see Geographic Targeting:
 Selected State Examples {U.S. EPA,
2.7  Developing Management Strategies
                   Before preparing a basin plan, the state identifies a range of
                   management strategies and evaluates their effectiveness.
                   Management strategies take into consideration the unique problems of
                   individual watersheds as well as constraining factors such as
                   resources available for control measures, legal authority, willingness
                   of stakeholders to proceed, and the likelihood of success.

                   The first step in developing management strategies is to establish
                   clear goals and objectives for addressing priority concerns. Goals and
                   objectives can be quite specific.  For example, a basin goal could be
                   to reduce or eliminate the incidence of algal blooms in an estuary; a
                   corresponding objective could be to reduce total phosphorus
                   concentrations in its tributaries by 30 percent.  The Klamath River
                   Basin highlight describes one goal and one objective that provide a
                   basis for management strategy development for that basin.  Similarly,
                   goals and objectives may be developed for certain watersheds.  See
                   Watershed Protection: A Project Focus (U.S. EPA, 1995) for further
                   discussion  of watershed goals.

                          2. MANAG.MGBVWflTERSHEDS;
                                                                  . „ ------
Goaf I:
           ^^                                      anad~ **
        •subsist, ceremonial,

          expectations       aataba*>. v,ew ex.stmg regulations as minimum
     fish habitat

     monitoring recov   of
                                              Kcurrent timber
                                              Wtat int89rity;
    i   ^* - ----<- ^••%**^yfl IX/^

    plans to protect highl, W1WWW

    unimpaired safmonid habitat."

Kiamath River Basin Restoration
                                                     "* monitoring

                                                 Rt"eS and F°rest Service
                                                    tO Prot««ion of

                               2.  MANAGING BY WATERSHEDS:  COMMON ELEMENTS
  Nutrient Trading in the Tar-Pamlico Basin

  The Tar-Pamlico Basin is designated as Nutrient Sensitive Waters (NSW) by the State
  of North Carolina* In 1989, state officiate were poised to establish strict new controls
  on point sources of phosphorus and nitrogen, believing at the time that point source
  controls were the only enforceable option. However, dischargers concerned about the
  high capital costs of the new controls formed the Tar-Pamlico Basin Association and
  worked with the state and two local environmental agencies to craft a nutrient trading

  The management strategy for the basin now calls for the Association to fund rural best
  management practices (BMPs) by contributing to the State Agricultural Cost Share
  Program, The investment by the Association was approximately one-fifth the amount
  that point source controls were expected to cost, and the reduction in loading to the
  nutrient-sensitive portion of the basin should be considerably larger than point source
  controls alone could achieve.
                   Some strategies developed for a management plan may be basinwide
                   in nature (e.g., phosphate detergent bans or incentives for riparian
                   protection) while others may be more local (e.g., improved animal
                   waste management in a watershed with a high concentration of
                   livestock operations).  Implementation of a basin approach allows
                   states to address large-scale problems and local issues at the same
                   time (see the "Nutrient Trading" highlight above).

                   Stakeholder involvement contributes to  equity in point and nonpoint
                   sources controls. Individuals are more likely to negotiate when their
                   knowledge of watershed problems is strong and they see that all
                   sources are being asked to make sacrifices. Figure 2-3 illustrates a
                   method for relating specific goals and objectives to stakeholders for
                   management strategy development. Effective statewide approaches
                   may provide opportunities for innovative management alternatives
                   such as pollutant trading, wetlands mitigation banking, and ecological
                   restoration.  (See Section 3.10 for additional  information on these
2.8  Management Plans
                   Management plans are critical. They document the process, the
                   selected management strategies, and stakeholder roles, and also serve
                   as a reference for future basin cycles.  Teams, composed of staff of
                   the state water quality, agricultural, public health and other state

                                     Partic patlng Program*, Agenclee. and other Stakeholder.
     OAL 1 - Control of Pollutant Inputs
                     Stormwater - Sewage
                       Overflow Control
                     Point/NPS Trading Program
                     NPS BMPs
  QOAL2 - Ecological Restoration
                    Channel Reconstruction

                    Water Flows

                    Redesign Diversion Structures

  GOAL 3 - Habitat PrMan/rtton
                    Conservation Easement
                    Wetlands Watershed Scale
                     Advanced Identification
           pupa. HeaHh/Drinidm.w
                    Puttte Water Suppftw
                     ProtectJon Policy
                    Wellhead Protection
                    Source Water ProtecUon
GOAL 5 - Biodi
                           leal I	
                   Improve Timing for Diversions
                   Contiguous Habitat Corridors
                   Species Landscape Needs
GOAL 6 . Su.tj.ln.Kj- p^	^
                  Eliminate Excessive Soil Loss
                  Public Outreach and

                     agencies, are responsible for developing the documents. Plans are
                     updated periodically thereafter.

                     Watershed management plans must specify how goals will be
                     achieved, who is responsible for implementation, on what schedule,
                     and how the effectiveness of the plan will be assessed. Clearly
                     defining an implementation step is a characteristic that separates
                     basin protocols from initiatives for planning purposes only.  Experience
                     suggests that formal commitments from all stakeholders are critical
                     before moving into implementation.

                     The highlight on page 2-19 shows a draft basin plan outline for the
                     Delaware Department of Natural Resources and Environmental
 2.9  Implementation
                    Upon completion and approval of a basin plan, the plan is
                    implemented.  Implementation activities may include issuance of
                    NPDES permits with conditions reflecting the plan provisions,
                    implementation of voluntary or mandatory BMPs to control NPS
                    pollutants, critical area protection, habitat restoration, a monitoring
                    program to measure success and guide future plan revisions, and
                    development of TMDLs.

                    As an example, the Neuse River Basinwide Water Quality
                    Management Plan (NCDEM, 1993) describes management strategies
                    for this basin and its watersheds.  For the first cycle, the Plan
                    describes point source controls in the Neuse Basin in considerable
                    detail.  NPS strategies for this cycle involve numerous existing
                    programs and prioritization of BMP funding.  In future cycles, North
                    Carolina anticipates including more detailed information about NPSs
                    and strategies.

                    Figure 2-4 shows the major steps identified by the Washington
                    Department of Ecology for its statewide approach.  Although the
                    terminology differs slightly, Figure 2-4 features all of the common
                    elements presented in this chapter.

                               ZJVJANAGING^Y WATERSHEDS: CQMMn*. c. C«E..~
   Basin Management Plans in Delaware

   1«  introduction/Summary

      1.1   Purpose of Plan
      t ,2   Whole Basin Planning Cycle
      1 -3   Participating Agencies and Publics
      1.4   Public Input Process
      1.5   Summary of the Management Plan

  2.   General Basin Description

      2.1  Physical, Geographical, and Ecological Features
      2.2  Overview of Potential Environmental Stressors
      2.3  Land4Jse/Umd Cover Characteristics
      2.4  Socioeconomlcs and Government
      2,5  Projected Trends in Basin Development

 3.   Existing Environmental Conditions, Uses, and Stresses

      3J   Land
      3,2   Water
      3.3   Air
      3.4   Resource Integration

 4.  Major Concerns and Priority Issues

     4.1   Issues of Concern
     4.2  Targeted Geographic Areas

 5.   Long Term Goals and Management Strategy

     5,1   Goals
     5.2  Options Analyzed
     5.3  Strategies Selected
     5.4  Measures of Success

6,   Implementation

     Area-Specific Implementation Activities

7.   Next Steps

                                       2. MANAGING BY BASINS: COMMON ELEMENTS
           • Other agencies
           • Dischargers
           • Tribes
           • Advocacy groups
            Drinking water
                                  1.  Public Outreach
                                  2. Canvas for Information
                                  3.  Analyze Information
5.  Determine Status of Basin Resources
6.  Identify Problems and Critical Issues
   Loading and Habitat
                                 7.  Define Management Goals
                                 8.  Prioritize Problems and Critical Issues
                                 9.  Evaluate and Describe Management Options
                                 10. Select Management Approach
                                 11.  Prepare Draft Basin Plan
                                 12. Review/Public Hearings
                                 13. Implement Approved Basin Plan
 Figure 2-4. Major steps in developing and implementing Basin Water Quality Management
                Plans (adapted from Washington Department of Ecology)

                                        3. WHY MANAGE BY WATFR.QHcno,


 3.! Water Qua.rty Program, Can Focus More Direcfly on the Resource

3.2  The Basis for Management Decisions is Improved

                                                3. WHY MANAGE BY WATERSHEDS?
                    • Focusing on basins and watersheds encourages agencies to seek
                      information on all significant stressors, including those that tend to
                      be overlooked by traditional programs (e.g., ecosystem effects due
                      to habitat loss).  This encourages monitoring programs to account
                      for the full realm of impacts and sources.

                    • The pooling of resources and data by multiple stakeholders tends to
                      increase the amount and types of data available for carrying out
                      assessments  and prioritizing problems for action.

                    • Basin-oriented monitoring may result in more detailed information.
                      In North Carolina, for example, approximately 38 percent more
                      monitoring sites  were sampled during the first full year than
                      previously, with  about the same level of  effort.

 3.3 Program Efficiency Is Enhanced

                    Focusing  on individual basins can improve program efficiency within
                    the State water quality agency.  For example:

                    • Coordinating  monitoring by basin results  in more efficient use of
                      staff and reduces travel time between sites.

                    • Modeling studies can be consolidated to  increase the stream miles
                      of waterbody modeled per unit of effort.

                    • NPDES permit notices can be consolidated by basin to limit the
                      number of publication documents; this requires adjusting permit
                      expiration schedules so that all permits in a basin have the same
                      expiration dates.

                    • Public meetings can be consolidated to cover multiple permits for a
                      given basin.

                    The  development of basin plans can also be a means  to achieve
                    compliance  with CWA mandates:

                    • Basinwide assessment results can support Section  305(b) reporting
                      if  a common database is used for basin plans and Section 305(b)
                      reports. For example, basin plans can include water quality
                      assessment text  and Waterbody System  data summarized by basin.
                      The Waterbody System can then  be used to generate the required
                      statewide summary results and tables for Section 305(b) reports.
                      In 305(b) reports, states may choose to reference the basin plans
                      for detailed assessment results, thus avoiding duplication  of effort.

                                                3. WHY MANAGE BY WATERSHEDS?
                    •  Basin plans can satisfy Section 303(d) reporting requirements since
                      strategies for addressing impaired waters (i.e., actual TMDLs) can
                      be included in basin plans.

                    •  TMDL development often requires a watershed approach.  EPA
                      regulations  and  guidance define a TMDL for a specific pollutant as
                      being equivalent to the loading capacity of a waterbody.  This total
                      load  includes both point and nonpoint sources. Since nonpoint
                      sources are often diverse and  widely distributed across a
                      waterbody's watershed, management strategies that affect the
                      entire watershed are often needed.

3.4 Coordination Among  Agencies in the  State Can Be Improved

                    A watershed approach can help clarify the role of the state water
                    quality  agency in relation to other natural resource agencies—those in
                    state and  local government as well as federal agencies, such as USGS
                    and  USDA, that have state and local offices.  Some tasks require site-
                    specific knowledge and close local contact; other tasks need state-
                    level authority or can be more cost-effective at that scale.  For
                    instance, the state water quality  agency is usually best equipped to
                    conduct laboratory analysis and monitoring and to provide oversight
                    for water quality standards and discharge permitting.  This agency
                    can  play a coordinating role to secure support from other state and
                    federal  agencies and leverage resources for multi-stakeholder efforts.

                    The  watershed approach  provides an umbrella under which local
                    programs  can  be reinforced and their consistency  with state- and
                    basin-level objectives ensured. Local agencies and organizations  may
                    be in the best position to develop detailed land use inventories,
                    organize workshops and educational programs, and implement  BMPs,
                    habitat  restoration  and protection, or land use controls.

                    Improved  efficiency may  also result from closer coordination among
                    programs. For example, Nebraska's Department of Environmental
                    Quality  hopes  to reduce the amount of time spent investigating citizen
                    complaints.  Through closer coordination, only one agency will
                    respond to each complaint and that agency will determine if further
                    action is needed. In Alabama, many water-related programs are being
                    coordinated  through the CSGWPP (see highlight).

3.5  Resources Are Better Directed to Priority Issues

                    A state  is  better able to focus its water quality program resources,
                    which are often dispersed among several  agencies, on those portions

                                                 3.  WHY MANAGE BY WATERSHEDS?
   Alabama's Us* of Its Comprehensive State Ground Water
   Protection Program to Coordinate Its Programs

   As a first step toward total water resource management, Alabama is coordinating its
   programs through its Comprehensive State Ground Water Protection Program
   (CSGWPB.  In developing its CSGWPPr the state recognized the unique challenges of
   ground water protection, including the enormous costs and technical difficulties c-f
   ground water remediation and the difficulty of locating sources of contamination due to
   the lag time between discharge of pollutants  at the land surface and their transport
   through an aquifer. These challenges emphasize the need for a coordinated state
   approach centering on common priorities.

   Alabama is implementing this coordinated prevention approach through its CSGWPP.
   All of Alabama's major environmental programs, including its waste programs, are
   located in the Alabama Department of Environmental Management.  In addition,
   Alabama has established the Water Programs Advisory Committee, which brings
   together all the major entities with ground water protection responsibilities.  Alabama's
   Department of Agriculture has been a full partner in this effort, Once the CSGWPP has
   been fully implemented,  all ground water-based programs wilt direct their efforts first at
   wellhead protection areas. Alabama is also in the process of developing a ground water
   classification system that will direct program priorities.  Currently, the state's
   Underground  Storage Tanks Program is focusing its inspection and prevention efforts in
   wellhead areas and is spending funds to heip delineate the state's wellhead areas.
                    of basins where they will do the most good.  The watershed approach
                    opens the door to statewide application of risk-based procedures for
                    targeting where and how program resources should be spent.  This
                    improved capability is primarily the result of three features of a
                    statewide approach:

                    •  Improved information bases and assessments more clearly identify
                      water quality issues and waterbody concerns for the process of
                      assigning priorities.

                    •  Systematic review of all basins as the state cycles through the
                      sequence allows for comprehensive review of within-basin needs
                      as well as comparison of resource needs among basins.

                    •  Improved coordination among stakeholders produces common
                     management priorities and promotes the leveraging of resources.

                                               3. WHY MANAGE BY WATERSHEDS?
3.6  Coordination with EPA Can Be Improved
                   EPA and the states are already working together on programs with a
                   watershed orientation and extensive stakeholder involvement.
                   Examples of such programs include

                   • Chesapeake Bay Program

                   • Clean Lakes Program

                   • National Estuary Program

                   • TMDLs with watershed-wide nonpoint  source issues

                   • Great Lakes Program (especially Remedial Action Plans and Lake
                     Management Plans).

                   Watershed approaches provide an opportunity for EPA and state
                   agencies to augment one another's efforts throughout the state, not
                   just in areas that fall under special programs.  In the long run, an
                   approach that serves to clarify roles, identify resource needs,  and
                   establish management priorities enhances the efforts of all partners.

                   States pursuing watershed approaches have identified several ways
                   that EPA can help facilitate the approach. EPA can:

                   • Issue program guidance that encourages long-term watershed
                     management goals rather than short-term program goals that might
                     draw resources away from the basin planning process

                   • Negotiate annual  or multi-year state program plan commitments
                     that  revise traditional reporting requirements (e.g., STARS/SPMS,
                     TMDLs, lists, reports)

                   • Provide for transfer of information so states can learn from
                     experiences throughout the EPA Region or the Nation

                   • Make basin planning efforts a priority under grant programs such as
                     the Sections  104(b)(3) and 319 programs

                   • Where feasible, Regions can work with states to ensure that grants
                     have compatible requirements and planning periods

                   • Assist in negotiations  involving other federal agencies or adjoining

                                                3. WHY MANAGE BY WATERSHEDS?
  Regional Flexibility to Accommodate the Transition

  North Carolina officials found that considerable time was needed to plan the state's
  basin approach.  Also, the first round of basin plans are more time consuming than
  plans will be in subsequent 5-year cycles. The state asked EPA Region 4 for permission
  to maintain existing effluent limits in cases where NPDES permits came up  for renewal
  ahead of the basin schedule (i.e., prior to the year when all the basin's permits are to be
  renewed}. If approved, state staff would not need to remodel each water quality-limited
  parameter, and permittees would not be penalized by different effluent limits upon the
  adoption of a basin plan in 1 or 2 years.  The state reasoned that major management
  decisions should await the improved technical analyses associated with the basin plan.
  Region 4 agreed that this interim flexibility would further long-range water quality
  management goals.
                    EPA Regional staff are aware that watershed protection is a new way
                    of doing business and are responding to these requests on a case-by-
                    case basis (see North Carolina highlight on this page).
3.7 Consistency and Continuity Are Encouraged
                    By focusing on goals to be achieved over several cycles, the approach
                    reduces the tendency to operate in a reactive or crisis mode.
                    Stakeholders can expect improved continuity in decisions because
                    management actions throughout the basin are fixed for at least the
                    length of a basin cycle.  Utilities directors, for example, can better
                    plan their long-term wastewater or water supply needs.

                    Improved consistency is possible because pollution sources across a
                    watershed  are evaluated within the same time frame, and because
                    management actions are subject to broad scrutiny during the planning
                    process.  Thus, for example, animal producers across a watershed are
                    likely to be subject to consistent impact analysis and management
                    measures.  Similarly, all  NPDES permittees along a major  river may be
                    studied at the same time using the same water quality model; the fact
                    that these stakeholders will be aware of the process  and  each others'
                    discharge limits tends to promote consistent and equitable permits
                    and may reduce the number of grievances filed by permittees.
3.8  Opportunities for Data Sharing Are Enhanced
                   Increased data sharing is an important benefit of any process in which
                   stakeholders from different organizations work toward common goals.
                   Most state  and local agencies have records and information systems
                   unique to their individual functions. In many states, for example,

                                                3.  WHY MANAGE BY WATERSHEDS?

                    NPS related data are housed in several agencies and are not readily
                    accessible to outside  parties.  Inaccessible data on land use and BMPs
                    present a significant limitation to some states' NPS efforts (see
                    highlight on this page).

                    Sharing and linking new computer technologies among different
                    agencies is also encouraged. Geographic  Information Systems (GISs)
                    can help analyze spatial data for entire basins using data from several
                    agencies, e.g., to show the relationship between  land use and
                    predicted nonpoint  source  loadings.  CIS buffering techniques are
                    being used to assess the needs for riparian habitat protection, to
                    design greenway systems, for biodiversity analysis, and for planning
                    wetland banking  programs, among other purposes.
3.9  Public Involvement Is Enhanced
                   Watershed protection focuses on a discrete resource around which
                   citizens can rally.  The approach promotes awareness of water-related
                   issues by citizens and encourages  agencies to respond to their
                   concerns.  Opportunities for this interaction occur during basin plan
                   development and activities such as workshops, hearings, and citizen
                   monitoring.  An additional benefit of public involvement is that a
                   better informed public can lead to increased citizen and legislative
                   support for water quality programs.
 Data Sharing in North Carolina

 During its first S-year basin management cycle, North Carolina is promoting data sharing
 among natural resource agencies* This initiative might have occurred without a basin
 approach, but the basin approach has accelerated the process.  Initially, a Sub-basin
 Database was developed  containing available data on point sources, land use,
 agriculture, and other NPSs by watershed for preparing  basin plans.

 Realizing the need for more detailed nonpoint source data, the state is consolidating
 NPS and BMP data from multiple agencies, including new information yet to be
 collected.  The Tar-Pamlico Basin will be the focus for system development, and the
 needs of state and toeal users and modelers will receive top priority. To the extent
 possible, spatially based information will be collected for GIS analysis,  The agencies'
 GIS data layers are maintained in the state's Center for Geographic Information and

                                                 3. WHY MANAGE BY WATERSHEDS?

 3.10 Innovative Solutions Are Encouraged

                    Some watershed problems, such as habitat destruction, inadequate
                    stream flow, wetlands loss, atmospheric deposition, and introduced
                    aquatic species, are difficult for traditional water quality programs to
                    address.  This approach can provide a strong framework for
                    identifying  and solving such problems.  Problem identification is made
                    easier by involving technical experts from many fields during the
                    environmental assessment portion of the basin cycle —aquatic
                    biologists working side by side with water resource engineers and
                    agricultural specialists, for example, can share data and perspectives
                    on a basin's stressors. Solutions are not limited by the authority or
                    expertise of a single agency, but rather encompass the range of
                    stakeholders.  Following are several nontraditional solutions that are
                    feasible under a watershed approach.

                    Ecological Restoration - Ecological restoration is the reestablishment
                    of physical, chemical and biological components of an aquatic
                    ecosystem that have been compromised by point and nonpoint
                    sources of pollution, habitat degradation, hydromodification, or other
                    stressors (Restoration  as a Water Resource Management Tool, U.S.
                    EPA  1994b).  Categories of restoration techniques include

                    •  Techniques applied  directly to the stream channel (e.g., channel
                      reconfiguration to restore geometry and sinuosity; streambank

                    •  Techniques applied  in the riparian zone (e.g., replanting of riparian
                      buffers to increase the canopy and other functions)

                    •  Techniques applied  outside the riparian zone that result in instream
                      improvements (e.g., BMPs that reduce stormwater surges and
                      improve riverine habitat).

                    Restoration  activities in the stream channel and riparian buffer zone
                    are much less commonly used than traditional point and nonpoint
                    source controls.  Yet, restoration  activities may be essential for
                    achieving ecological integrity.   Examples include:

                    •  Chronic sedimentation and catastrophic blowouts caused by
                      logging roads; such  occurrences may be  unavoidable  on  steep
                      terrain, despite engineered BMPs.  Revegetation and road
                      decommissioning may be necessary to restore instream habitat.

                                               3. WHY MANAGE BY WATERSHEDS?
Providing Fish Passage

On regulated  river systems, impassable barriers sometimes block the migrations of
anadromous fishes.  The most dramatic cases involve  salmon stocks on the Columbia
River system in the Pacific Northwest, where dams either interfere with fish passage or
in the  case of structures like the Grand Coulee Dam, preclude  migration altogether,'
Other obstructions may be less obvious but equally deleterious.  For instance,  culverts
and minor flood control structures around bridges or stretches of a channelized stream
can block the migrations of shad or rock fish. Eliminating such minor blockages is a major
goal of the Anacostta River Restoration Project in Maryland and the District of Columbia.
On larger systems, retrofitting fish ladders or elevators may be viable options.
                  • Barriers to fish passage that may prevent reestablishment of
                    important fish species, regardless of water quality (see the highlight

                  • Waterbodies with toxics-laden sediments that must be removed
                    before healthy aquatic communities can reestablish themselves.

                  In many cases ecological restoration may be the most cost-effective
                  way to achieve watershed water quality goals.  The highlight on
                  page 3-10 describes a case in which habitat restoration was
                  preferable to advanced wastewater treatment.

                  Protection of Critical Areas - The National  Research Council recently
                  cited promising examples of restoration projects that have restored
                  functions in small wetlands, stretches of  streams, and small lakes
                  (National  Research Council, 1992).  However, the study did not find
                  cases where populations of fish or wildlife were restored on a broad,
                  regional scale.

                  Fortunately, long-term  biological integrity in a watershed may be
                  possible through a watershed-wide strategy of protecting and
                 restoring high  priority areas such as headwaters, riparian buffers, and
                  biotic refuges.

                 Traditional CWA programs may not protect these areas. In many
                 watersheds, for example, headwaters and riparian buffers do not
                 receive protection as wetlands under CWA Section 404.  The loss of
                 these areas may reduce or eliminate future opportunities for healthy,
                 balanced biological communities and  good habitat.  In other words, an
                 "ounce of prevention" by protecting key areas in a watershed may be

                                                  3. WHY MANAGE BY WATERSHEDS?
   Ecological Restoration as a Cost-effective Solution

   In addition to meeting the needs of living resources, ecological restoration or habitat
   protection can sometimes increase the capacity of a system to assimilate and
   transform pollutants,  in Boulder Creek and the South Flatte River in Colorado, city
   governments rebuilt natural flood plain meanders and reestablished natural channel
   depths and near-stream vegetation patterns. These restoration efforts helped reduce
   the concentrations of unionized ammonia in reaches downstream of the cities of
   Boulder and  Denver.  This in turn eliminated the need for costly sewafle treatment
   pfant upgrades.
                     the only way to ensure long-term ecological integrity and avoid the
                     costs of restoration in the future.

                     B/otic refuges are areas with relatively undisturbed habitat that
                     maintain aquatic  biodiversity.  They may include the headwaters
                     portion  of a watershed or undisturbed riverine segments. A
                     watershed may also contain many smaller patches of intact aquatic
                     habitat  (e.g., undisturbed small lakes or stretches of stream with deep
                     pools for fish habitat). These biotic refuges and smaller patches may
                     have been  protected by fortuitous land ownerships or simple chance.
                     Scientists now recognize that the restoration of ecological integrity
                     across a watershed or a basin may depend on identifying these
                     special areas and protecting them from disturbance  (development
                     pressures and point or nonpoint sources).

                     For further information on protection and restoration of ecologically
                     important areas, see U.S. EPA (1994b), National Resource Council
                     (1992),  Doppelt et al.  (1993), and  Moyle (1992).

                    Wetlands Mitigation Banking  - This approach has emerged as an
                    alternative to onsite compensation for wetlands loss. In wetlands
                    mitigation banking, larger offsite wetlands are used to mitigate for
                    many smaller development projects.  Developers purchase
                    "compensation  credits" from the mitigation bank.  Wetlands in the
                    bank are created,  enhanced, restored, or preserved for this purpose
                    (Environmental  Law Institute, 1993).

                    Wetland mitigation banking potentially can provide greater ecological
                    benefits than onsite, project-specific mitigation-e.g., if the
                    compensation sites are larger and more viable hydrologically and
                    biologically.  Also, continuing  professional wetland management is

                             3.  WHY MANAGE BY WATERSHEDS?
more likely to protect water quality than ad hoc management at
isolated sites (Environmental Law Institute,  1993).

Ideally, wetlands management will become  integrated within
comprehensive management programs and the policy of "no net loss"
implemented by basin or watershed unit.  This approach could provide
water quality benefits for the entire basin.

Market-based Solutions - Market-based approaches such as pollutant
trading do not have a long history, but some states are developing
promising approaches. Pollutant trading between point and nonpoint
sources may be feasible in cases where one source category is facing
large  costs to control  pollutants common to other sources.  For
example, point  source dischargers may find it cost effective to
provide funds for nonpoint source controls or ecological restoration
rather than to add additional treatment.  One example is nutrient
trading in the Tar-Pamlico Basin of North Carolina, where a
consortium of municipalities and other point sources has agreed to
fund the  State Agricultural Cost Share program for nutrient BMPs in
the basin (RTI,  1995). Other market-based applications include
wasteload allocation trading among point source dischargers on the
same river.  Local governments can play a facilitation role in such
approaches.  In South Carolina,  for example, the Bureau of Water
Pollution  Control hopes to involve  regional councils of government in
wasteload allocation decisions.


                                                              4.  GETTING STARTED

                    wah   .« t 9 H   ' SWItChin9 fr°m Pr°9ram-centered to
                    watershed-centered management involves a fundamental change that
                    will prompt intense scrutiny by staff and administrators. Although
                    ^vid3,^   T1^ Chan9eS '" ^^'relationships among 9
                    .nd,V1duals and programs, it does not necessarily require a change in
                    orgtn.zat.onal structure.  Nonetheless, a significant investment of
                    time rs needed to resolve such issues. The use of skilled outside
                    The process is unique to each state (see highlight next page).

                                                       Stat6S face seve'al '
                   •  Establishing a common direction
                   •  Managing the transition
                   •  Identifying barriers
                   •  Documenting the approach.

                   These challenges and some ways to address them are described in
                   the followmg sections.  EPA understands that this is not the only way
                   ™lCath    " 3 IT"1 approach'  Rather' the information beovT
                   states to     meS    teChniqUeS that have P™" useful in several
4.1  Establishing a Common Direction
                   have d«fearndtPr0gramS lnV°'Ved in wa'ershed protection are likely to
                   have different perspect.ves and goals.  Successful development
                           °      9 'eaderShiP and SUPP°rt frOm each Participating
                                            m StaH "^ Want a clear direction'and
                                     °re a£|reelng to P*«ciprte.  This "buy-in"  to the
                                           a demonstration °f

                                                                   GETTING STARTED
   Implementing Statewide Approaches in Delaware and Texas

   In Delaware, managers from two separate divisions within the state's Department of
   Natural Resources and Environmental Control recognized the limitations of operating
   nonmtegrated programs.  These managers brought together their staffs and
   representatives from several other agencies. Through a series of workshops and
   workgroups, they are developing a core program to integrate the activities of the
   Division of Water Resources programs (i.e., surface water, ground water, wetlands)
   with the activities of the Division of Soil and Water Conservation Programs (i.e., NPS
   management, coastal zone management, sediment, and stormwater).

   The Stale of Texas initiated a process after a Division Director brought the approach to
   the attention of both the Deputy Executive Director and Chairman of the Texas Natural
   Resources and Conservation Commission. These top^ievel administrators, in turn  have
   instituted an agency-wide review for application of the  approach to ail programs, A
   series of educational and discussion sessions led to the establishment of internal
   workgroups to address preliminary issues and provide the foundation for development
   of a basin approach.
                    Administrators can demonstrate their commitment by developing a
                    mission statement that supports the concept of basin- or watershed-
                    centered management. Meetings can be held with staff and
                    managers to develop consensus regarding goals and objectives.  The
                    expected products (e.g., basin plans, technical references) and
                    services (e.g., assessment, planning, outreach) should be specified
                    from the outset.
 4.2 Managing the Transition
                    State agency staff and other stakeholders will be very interested in
                    how the operation of programs will change to accommodate
                    watershed management.  Several steps can be taken to assure
                    stakeholders that a smooth transition can be accomplished.

                    •  Determine who will direct development:

                      Planning all the details of basin schedules, stakeholder
                      responsibilities, monitoring plans and other activities is  a significant
                      effort.  To lead this effort,  it is important to have a knowledgeable
                      person with strong communication and organizational skills.  The
                      leader may select a core group of contacts throughout  the
                      stakeholder agencies to advise and act on process issues.  The

                                                               4. GETTING STARTED
                    •  Establish a resource base for development:
                                  i watershed approach will require an expenditure of
                       start time to plan, document and implement the approach
                       Therefore, it is helpful to determine, up front, the availability of
                       n,,atJJ!SOUr?eS' -°ther resources such as federal assistance or
                       outside contracting services can be explored.

                    •  Educate participants on statewide management:

                       Educate all staff likely to be involved in the process on the
                      fundamental concepts.

                    • Establish a means of communication among participants:

                      Given the significance  of the process, agencies should not rely on
                      information to trickle down through supervisors to staff
                      is recommended that reaches all participants directly.   '
4.3  Documenting the Approach
                   The lead agency should prepare a document that describes the
                   approach for that state.  This document, often referred to as the
                   framework document (see Figure 1-3), should include the overaN aoals
                   and ob,ect,ves for participating agencies, a definition of the      ®
                   management units for the state, the basin cycle schedule procedures
                   for develop^ basin plans, roles and responsibilities of pa^dpattg
                   programs and agencies, targeting criteria and procedures and
                   gu,del,nes for public involvement.  The framework document serves
                   and nWT" 7*ere?Ce f°r Staff to ensure <=°™stency °f application
                   and quahtv of results. The document also often serves to
                   cornmun.cate to the public what the approach involves and how they
                   can better participate in the process.                             V
                  faturesmmnt     ** f framework do<=^«nt that contains
                  features common to several states. The next highlight  presents some
                  of the .ssues bemg addressed by the Delaware Department I" Natu^!
                          8 "  Envir°nmental Contr°' '" Developing a framewort for

                                                                           4.  GETTING STARTED
                   Executive Summary

                   Statewide Watershed Management Approach Vision
                           Long-Term  Basin Management Vision
                           Relationship of Current Basin Approach to Vision







 1.1    Objectives
 1.2    Rationale for Approach
 1.3    Federal CWA  Mandate for Approach

 Coordination/Integration  of Agency Programs and Functions
 2.1    NPDES Permitting
 2.2    Monitoring
 2.3    Financial Planning and Grants
 2.4    Water Resource Planning
 2.5    Nonpoint Source Programs
 2.6    Coastal Zone Management
 2.7    Drinking Water
 2.8    Ground Water
 2.9    Fish and Wildlife
 Transition Issues and Solutions
 3.1     EPA Flexibility
        Organizational Structures
        Coordination with Local Planning Agencies
        Basin Scheduling Process
        Other Issues
Major Components of a Basin Management Plan

Procedures for Developing Basin Management Plans

Statewide Monitoring Plan

Data Analysis, Modeling, Presentation (TMDLs)

State Financial Assistance

Roles and  Responsibilities in Basin Approach
9.1    Surface and Ground Water Quality
9.2    Soil and Water Resources
9.3    Other Divisions

Implementation Schedule

Data Management
11.1   GIS
11.2   Existing Data Management Structures
11.3   Recommended Data Management Structures
                   Figure 4-1.  Example framework document outline.

                                                                4.  GETTING STARTED
   Key Issues Addressed by Delaware in Developing a Basin Management Framework

      *  A primary goal in Delaware is to restore and preserve physical habitat that is
         essential to waterbody integrity.

      •  The Division of Water Resources will phase-in coordination with other divisions
         and agencies,  The consensus strategy recommended that the Division take the
         lead in the early phases of development and implementation. This will provide
         the program with a base of CWA authority and precedence. However, the
         program description includes a definition of water quality inclusive of biological
         resources, physical habitat, and watershed linkages to ensure that the Division's
         approach is consistent with the goals and objectives of programs and agencies
         that will be partners in subsequent phases. The Delaware approach will
         ultimately include many of the natural resource programs including the Fish and
         Wildlife Division, the Parks and Recreation Division, and county ptannino

     •   A statewide monitoring program addresses targeted needs for individual  basins
         (e.g., rotating stations and intensive  surveys) and maintenance of a statewide
         network for monitoring water quality status and trends.

     •   Transition issues raised in Delaware will require solutions,  They include EPA
         flexibility, workload planning, coordination with local planning agencies,  and
         scheduling basin rotation.  Delaware  is working actively with EPA Region 3 to
         make grant funding schedules and requirements more consistent,

     •   The process for funding through the traditional State Financial Assistance
         process presented an institutional barrier for implementation. Alternatives
         involving a geographically targeted risk-based approach are discussed in the
         framework document.

     •   Changes to current information management practices are also necessary.
         Information management is an important issue for most states, especially
        because the WPA focuses more attention on environmental  assessment and
        involves information from a larger number of data  sources.

  {see also  Delaware Department of Natural Resources and Environmental Control, 1994)
4.4  Identifying Barriers
                   State agency policies or even individuals may pose obstacles to
                   developing a basin approach.  For example, an agency policy or
                   regulation may have provisions contrary to the proposed approach or
                   a key individual may fail to participate in the development process.

                                                               4.  GETTING STARTED
                    There may also be staff resistance if organizational changes are
                    necessary to implement the approach.  Because the approach
                    encourages direct networking among technical experts in different
                    program areas, some supervisors may have difficulty with the
                    changing supervisor/staff relationship.  For example,  biologists and
                    engineers might need to work more directly with their peers in other

                    To identify concerns and risks of switching to a basin approach,  some
                    states have used a workshop setting and outside facilitators who
                    have no vested interest in the approach selected.  Positive outcomes
                    may include reduced level of concern and  new ideas  for resolving
                    issues.  Workshops  and workgroups are especially useful for issues
                    that can be resolved in a relatively  short time.  Involving a skilled and
                    impartial facilitator can also help mediate difficult, long-term issues.

                    To identify potential impacts to  agencies, it may be helpful for states
                    to consider the following questions:

                    • Will organizational changes be necessary?

                    • How will changes in  methods affect  staff and training?

                    • Are additional resources needed?

                    • How will the state's  relationship  with EPA/other agencies be

                    Once a basin approach  has been established, educating the public is
                    critical to building support for the approach.  Potential methods
                    include briefing state and local agencies, commissions, and special
                    interest groups about the process and what roles they can play.  This
                    important step may be  difficult for states to accomplish when so
                    much staff energy is going into developing the basin approach.
4.5 Tailoring the Approach
                    Once issues of direction and administration have been resolved, a
                    state is ready to develop an approach that will best meet its needs
                    and objectives.  Answers to the following questions  will guide this

                    •  What are the appropriate management units (i.e.,  basins and
                      watersheds) to be used  by all participants?

                      As discussed in Chapter 2, basin boundaries should be established
                      as a baseline for all participants in the management process.  Too

                                                       and basin
     Resource constraints -available staff and funding

                         6 ^^ -^ ^
     Balancing workload from year to year (e.g., in permit

                                                •"- Z-n Plan
        e' °f tCtiVI'ty ln a basin~a state maV want to begin with
                    "* antial information and mana9emen<
-  Anticipated degree of public involvement-a state may prefer to
    address f.rst those basins with a high degree of puWic interest
    and wlhngness to implement management initiatives

Which programs should be involved?

Decide which programs should  be integrated  (e.g., surface water

             drinkin9 W3ter' W6tlandS' agricultu'ai ««»S «S '
            Some states may choose to initiate a basin approach

 otherDrorateS °"'V ' feW Pr°9rams and P|an to incorporate
 other programs once some success has been demonstrated.

 the^L0,tTn'l0r'n9 m,aV be the first pr°9rams incl""ed due to
 the expected substant.al gains in efficiency from coordinating these
 acmmpes wrthin a basin management cycle.  Other statesmay
 choose to innate an approach that includes all water quality
 programs.  See the next highlight regarding  the integration  of

 aoaDSroaafhUtSettS drinki"9 Water Pr°teCti0n »r°9ram wi»" ^  basin
 approach to resource management.
mavfH>S df f rmi,nati°n °f Which Pr°arams to include, a state
may find ,t useful to hst in detail the tasks required to implement
basin management (e.g., data collection, data analysis and
assessment, priority setting, TMDL development, public
LtoSI?0^ Pla" P'Jeparation and adoption, permitting,  and other
elements).  Roles and responsibilities can then be identified for

                                                              4. GETTING STARTED
 Comprehensive Source Water Protection In Massachusetts

 EPA is actively promoting development of CSGWPPs,  Massachusetts is currently
 working to develop a CSGWPP aimed at integrating protection of both surface water
 and ground water sources of drinking water using EPA's CSGWPP Guidance as a
 model. Through this process,  the state has begun to identify inconsistencies and gaps
 in the protection programs for both ground and surface water-based drinking water
 supplies and to develop recommendations and actions necessary to address those

 A critical part of Massachusetts' current effort is the integration of the state's drinking
 water protection program with its river basin approach to resource management.  With
 development of its Clean Water Strategy in t993, the state started synchronizing
 functions within each basin that had previously been carried out in isolation within
 discreet water protection programs:  water quality monitoring; water withdrawal
 permitting {new wells); mitigation and remediation of nonpoint sources of pollution; and
 permitting under NPDES, Each of these activities impacts drinking water supplies as
 well as other waters of the state in some way, and drinking water supplies  are critical
 resources to be protected in each  basin. The state's strategy is ultimately to combine
 ground water and surface water protection program efforts into a unified Source Water
 Protection Program which wilt provide protection for aJJ sources of drinking  water
 throughout Massachusetts*

 Specific issues to be addressed during development of its Source Water Protection
 Program include:  te) defining surface water protection areas for reservoirs and river
 intakes of varying sizes and types  and identifying appropriate land use restrictions in
 those protection areas; {bj alleviating problems resulting from highway runoff to surface
 water supplies; and (c) developing a policy for disposal of water supply-generated
 sludge in drinking water protection areas. Additional opportunities for integration of
 drinking water protection into  the state's basin approach will be identified as the
 program is developed further.
                   completing these key tasks, thereby identifying the programs and
                   stakeholders that need to be involved.

                   •  What are the desired levels and methods of public participation?

                      Determine how and to what degree the public will be involved in
                      the process. Potential areas for participation include:

                      -  Data and information collection

                      -  Prioritization of problem waterbodies

                                           4.  GETTING STARTED

      Development of management strategies

      Review of management plans and implementation strategies

                     ion (e.g., by NPS agencies and local
   Determine whether the public will have open access to the

                                 °r be limited <      °
  What interactions among programs are key to effective
  implementation of the approach?
                 h                by Products or servic°* from
  other programs  but are not currently interacting at the most
  effecfve level. Some agencies have found it useful to develop a

                                   the reciuired Cements o? the
                                                    basi" 'Vole
 Work with stakeholders to establish a schedule for key task
 <          that corresponds t0 the overal1 basin management
                OUd the" idemifV imerim products tha< win be
                  S preparatlon 'e-a- monitoring  summaries,
        h      "SSef SmentS) and establisn tne format in which they
                 d  a"d the SChedule bv which theV should be
 thann       'S particular|V imP°«ant to identify those products
 that one program area must receive from another before work can
 proceed, smce bottlenecks can affect basin plan preparatton and
 .mplememat.on.  Often, the review/revision of interim products fs
 necessary before they can be used in the next steps of planning

 Appendix B shows a  detailed schedule of activities for Nebraska.

 To date nearly all states that have adopted basin approaches (or
      wTthe8!,"8"' are Synchron™9 NP<*S permit expiation
      with the basin management  time cycle.
               Pr°9uram JS SUCh a large Part of a Date's water
       agency, synchronizing permits makes it easier for this
actmty to be integrated with other components (planning

                                                               4. GETTING STARTED
                      monitoring, etc.).  In fact, increased permitting efficiency was the
                      initial reason that several States such as South Carolina adopted a
                      basin approach.  However, a state could choose  to bring other
                      programs into the cycle and let permit issuance remain on its own
                      schedule, incorporating  permits into the basin plans.

                      If permitting is synchronized with the basin management cycle, it is
                      recommended that permits expire shortly after the scheduled basin
                      plan adoption  date so that plan recommendations can be
                      incorporated into the permits and results can be tracked prior to the
                      next basin plan update.  For large basins with many NPDES
                      dischargers, permits may need to be issued over  a longer period of
                      time to spread out the workload for agency permitting staff.
                      Permittees can be grouped by sub-basin in this case so that
                      consistency and efficiency factors (e.g., consolidation of public
                      notices and hearings)  can be maintained.

                    •  What criteria will be used  to prioritize specific waterbodies and
                      watersheds within basins  for management action, and how will
                      agency resources be targeted to address specific concerns within
                      those prioritized  waterbodies?

                      In light of resource constraints, participating programs will need to
                      establish criteria to prioritize waterbody segments, watersheds,
                      pollutants of concern, etc., for effective management.  Because
                      objectives may differ across programs, it is useful to make
                      prioritization criteria explicit so that program involvement remains
                      efficient and consistent.  See Section 2.6.

                    •  What resource or technical support needs must be addressed
                      before the approach can be implemented?

                      Determine the specific needs of participating programs for
                      implementation (e.g., information  management systems, GIS, and
                      modeling capabilities).

                    •  How will basin plans be used?

                      Establish the intended audience(s) and purpose(s) of your basin
                      plan, identify the level of plan approval that will be required, and
                      outline the anticipated components of a basin plan.  See the
                      highlight  concerning Nebraska's decisions about the role of basin

                                                             4.  GETTING STARTED
Th* Role of Basin Plans in Nebraska
   Level of Approval

   *  l^l^8"^8"8 Sh°uW be official|y ad°Pted a* CWA Section 303(e) plans
      which require si9nature of the Governor and approval by EPA

                         plans should be prepared for approval b* the

   Audience and Purpose

   *   NDEQ-provide for coordination and direction of programs

   *   Natural Resource Districts -provide for information transfer; raise awareness-
      assrst coordination and implementation                        awareness,

   *   Other state and federal agencies -inform; direct activities and plan implements

  •   Begulated community- raise awareness of process; communicate reasons for

      effluent limitations (education tool); aid long-range planning

  •   Legislature^communicate; raise awareness of process and resource

      needs/legislative needs

  *   General public -increase awareness of  process;  improve perception* facilitate
      participation; hefp direct citizen monitoring efforts       P*0**™' tac.lttate

      £PA~address program plan requirements; expedite required  approvals; indicate

     resource needs; a
                                                             4. GETTING STARTED
                     Once implemented, how will the basin approach and its component
                     programs be administered?

                     It may be helpful for states to review operating agreements or state
                     programs supported by federal funds to identify areas where
                     revisions or consolidation are needed.  Multiple grants often result
                     in complex administrative burdens.  Consultation with EPA and
                     other participating federal agencies may result in possibilities for
                     block grants or other mechanisms to encourage program
                     integration.  Where feasible,  program plans should  be revised  to
                     support implementation. Also, new interagency memoranda of
                     understanding may be needed.


                                                                 5. REFERENCES
                  Delaware Department of Natural Resources and Environmental
                  Control. 1994.  Draft Delaware Basin Management Approach-
                  Statewide Framework Document.  Draft.  Dover, DE.
                               A                       " Karr  1993'
                             A New Approach to Save America's River Ecosystems
                  The Pacific Rivers Council. Island Press. Washington, DC and
                  Covelo, CA.

                  Environmental Law Institute.  1993.  Wetland Mitigation Banking
                  Washington, DC.

                  Inland Waterways Commissions. 1 908.  Report to Congress of the
                  Inland Waterways Commission. Washington, DC.

                  Klamath River Basin Fisheries Task Force. 1991. Long Range Plan
                  for the Klamath River Basin Conservation Area Fishery Restoration
                  Program. U.S. Fish and Wildlife Service.  Yreka, CA.

                  Moyle, P.B.  1992. Fishes, aquatic diversity management areas, and
                  biodiversity.  California Policy Seminar, University of California
                  Berkeley, CA.

                 National Research Council.  1992.  Restoration of Aquatic Systems •
                 Science, Technology, and Public Policy.  Washington,  DC.

                 NCDEM (North Carolina Division of Environmental Management)
                 1 993. The Neuse River Basinwide Water Quality Management Plan.
                 Raleigh, NC.

                 Nebraska Department of Environmental Quality, Water Quality
                 Division and The Cadmus Group. Draft Basin Management Approach
                 Framework Document for the State of Nebraska. Lincoln, NE

                                                                5. REFERENCES

                 RTI (Research Triangle Institute).  1994. Nutrient Modeling and
                 Management in the Tar-Pamlico River Basin.  Draft report for the
                 North Carolina  Division of Environmental Management. Research
                 Triangle Park, NC.

                 RTI. 1995.  Cost Effectiveness of Agricultural BMPs for Nutrient
                 Reduction in the  Tar-Pamlico Basin.  Prepared for the North Carolina
                 Division of Environmental Management.  Research Triangle Park,  NC.

                 South Carolina Bureau of Water Pollution Control.  1993.  Watershed
                 Water Quality Management Plan for the Savannah-Salkehatchie Basin.
                 Columbia, SC.

                 U.S. EPA (Environmental Protection Agency). 1991.  The Watershed
                 Protection Approach: An Overview.  EPA 503/9-92-001. Office of
                 Water.  Washington,  DC.

                 U.S. EPA.  1993a. Final Comprehensive State Ground Water
                 Protection Program Guidance. EPA100-R-93-001.  Office of
                 Administration and Resources Management.  Washington, DC.

                 U.S. EPA.  1993b. Geographic Targeting: Selected State Examples.
                 EPA-841-B-93-001.  Office of Wetlands, Oceans, and Watersheds.
                 Washington, DC.

                 U.S. EPA.  1993c. Solutions Basinwide. Video prepared for the
                 Office of Wetlands, Oceans, and Watersheds by RTI. Washington,

                  U.S. EPA.  1994a. National Water Quality Inventory:  1992 Report to
                  Congress.  EPA  841-R-94-001.  Office of Wetlands, Oceans, and
                 Watersheds. Washington, DC.

                  U.S. EPA.  1994b.  Restoration as a Water Resource Management
                  Tool.  Draft.  Office of Wetlands, Oceans, and Watersheds.
                  Washington, DC.

                  U.S.  EPA. 1995.  Watershed Protection: A Project Focus.  EPA 841-
                  R-95-003. Office of Wetlands, Oceans and  Watersheds.
                  Washington, DC.

                  Washington State Department of Ecology.   1994.  Watershed
                  Approach to Water Quality Management: A Strategy to Convert the
                  Washington Department of Ecology Wastewater Permit Function to an
                  Implementable Watershed Approach.  Olympia, WA,

             Appendix A
How Does Ground Water Protection Fit?


                                                                      APPENDIX A

A.1  Perspective
                   Considerable concern has been expressed by water resource
                   managers about how ground water protection is integrated with a
                   statewide basin approach.  The need for integrating surface and
                   ground water is clear since the quality of ground water contributes to
                   the general  condition of a watershed and may serve as a medium for
                   transporting pollutants to surface waters.

                   Furthermore, by coordinating the state's basin approach with its
                   Comprehensive State Ground Water Protection Program (CSGWPP), a
                   state may be able to leverage the authority and resources of programs
                   outside the  normal surface water management arena. Starting in
                   1984, EPA  began working with states to create ground water
                   protection strategies to coordinate efforts under some 20 federal
                   ground water programs.  There are ground water provisions focusing
                   on hazardous  substances impacts through programs under the
                   Resource Conservation and Recovery Act and the Comprehensive
                   Environmental Response, Compensation, and Liability Act governing
                   waste disposal sites and  remediation of Superfund sites.  Initiatives
                   under the Federal Insecticide, Fungicide and Rodenticide Act regulate
                   the use of agrichemicals.  The  Safe Drinking Water Act encourages
                   states to develop Wellhead Protection Plans and allows the
                   designation  of Sole Source Aquifers to provide additional safeguards
                   from the impacts of various federally assisted projects.

                   The states'  CSGWPPs integrate these various programs and activities.
                   Also, many  states use surface  water quality standards under their
                   CSGWPPs to provide  site-specific ground water protection standards.
                   Thus, a state's CSGWPP and its basin management activities  can
                   reinforce each other's goals. In fact, the effectiveness of the state's
                   basin approach may depend on how well these basin management
                   activities and the CSGWPP integrate important regional or site-specific

                                                                        APPENDIX A
A.2 Surface/Ground Water Issues at the Basin and Watershed Levels

                    Basin management plans under a statewide basin approach should
                    identify surface/ground issues at both the basin and watershed level.
                    At the basin level, certain issues tend to be broad in scope,
                    sometimes extending across all or part of a basin, for example:

                    •  Large areas of Kentucky, Tennessee, Virginia underlain with
                       limestone caverns where land disposal or direct pollution of
                       sinkholes can rapidly contaminate both surface  and  ground water
                       for many miles

                    •  Parts of Florida with underlying coral and limestone  formations and
                       underground  streams

                    •  The Eastern Snake River Plain  Aquifer, where activities in the basin
                       (e.g., irrigation, Superfund sites) have the potential  of
                       contaminating both the aquifer and the Snake River itself; the
                       aquifer is now designated as a Sole Source Aquifer

                    •  Portions  of Arizona and elsewhere in the arid west where activities
                       such as agriculture or mining tap into alluvial aquifers, draining
                       them and causing  loss of critical riparian habitat

                    State basin  management plans  also identify watershed-specific issues
                    for special attention in future watershed projects.   Examples of
                    watershed-level issues affecting surface and ground water include
                     localized problems with solid waste disposal in sinkholes, protection
                     of springs, pollution of surficial aquifers by land activities, and
                     localized sites where  recreational activity in caverns has caused
                     damage to sensitive aquatic biota.

 A.3 Challenges Specific to Ground Water Protection

                     There are many opportunities for integrating surface water and ground
                     water protection.  This is particularly the case where shallow aquifers,
                     which are often highly susceptible to contamination, are directly
                     connected to surface waters. In other  respects, however, ground
                     water protection presents challenges that differ in kind or scale from
                     those encountered in protecting  surface waters.   For example, given
                     the enormous  costs and technical difficulties of ground water
                     remediation, considerable  emphasis must be placed on pollution
                     prevention.  In contrast, because surface waters are generally easier
                     to clean up, greater emphasis under surface water programs can be
                     given to restoring impaired waterbodies.

                                                     APPENDIX A
Other ground water-specific concerns that should be considered when
designing broad protection  approaches  include ground water pollutant
fate and  transport mechanisms, monitoring considerations and
resource  boundaries, (e.g.,  aquifer boundaries may not coincide with
basin boundaries).  Because ground  water generally flows slowly,
there is often a long lag time (sometimes decades) between discharge
of pollutants at the land's surface and their transport through an
aquifer.  This may make it difficult to locate sources of contamination
and has obvious implications for enforcement and for evaluating
environmental effectiveness of protection efforts. Ground water
problems thus are often treated as nonpoint source pollution or in-
place contaminant concerns.

Monitoring ground water quality involves sampling existing or new
wells for  pollutants of concern.  Monitoring ground water can be very
expensive compared with monitoring surface water, especially if a
large network of new  monitoring wells must be installed and
extensive laboratory analyses of ground water consistent with the
state's priorities and schedules are implemented.

CSGWPPs should be carefully coordinated with the state's general,
long term Watershed Protection Approach. For maximum
effectiveness in protecting water resources, states need to make
conscious decisions on how CSGWPPs  and basin approaches can
most profitably align.  The following highlight  describes how Nebraska
deals with interrelated ground water and surface  water pollution

                                                                      APPENDIX A
 Unking Surface and Ground Water Management in Nebraska

 Nebraska's basin approach includes both surface water and ground water programs.
 Although the approach is not designed specifically for ground water, various ground
 water protection programs within the state are moving to a more basin-by-basin
 approach.  The state's Wellhead Protection Program annually targets communities in
 selected basins to receive a more focused Wellhead Protection effort.  Also,
 educational activities in Nebraska's CWA Section 319 nonpoint source program are
 coordinated with the state's basin approach.  Furthermore, septic tank and
 underground injection control program activities are targeted to different basins in
 successive years.

 In addition to these state-level activities, ground water management plans for dealing
 with ground water supplies and nonpoint sources of contamination have been
 developed and implemented by each of the 23 Natural Resources Districts (NRDs) that
 cover the state.  Basin plans wilt be coordinated with the ground  water management
 plan for each appropriate NRD. Since the Districts'  boundaries generally follow basin
 delineations, they provide a logical geographical management unit for coordinating
 watershed protection activities at the local level. The NRDs already sponsor a  large
 number of CWA Section 319 nonpoint source implementation projects across the
 state.  Several NRDs have worked with the Nebraska Department of Environmental
 Quality to develop and implement Special Protection Areas, while other NRDs have
 independently developed and implemented their own Ground Water Quality
 Management Areas.  Both designations deal with the management of nonpoint source
 ground water contamination.  Consequently,  although ground water activities in
 Nebraska are not specifically included in the basin approach, in effect the state's high-
 priority ground water concerns are being addressed basin by basin.

      Appendix B

Management Cycle for the
    State of Nebraska


                                                                       APPENDIX B

Management activities within Nebraska's thirteen delineated basins will be coordinated
around a five-year cycle.  A series of steps are executive for each basin over the cycle,
ending with the promulgation and implementation of a management plan.  These steps are
illustrated in Figure 1 and described below  in more detail.

Step 1.  Draft Strategic Monitoring Plan

                   A strategic plan will be drafted that specifies monitoring to support
                   basinwide assessment.  Details shall include monitoring  objectives,
                   station locations,  parameter coverage, sampling frequency, and
                   monitoring plan rationale.

Step 2.  Initial Public Outreach

                   As resources allow, NDEQ will hold public meetings at appropriate
                   sites within the basin to acquaint stakeholders with the  overall
                   framework and help identify management concerns specific to that
                   basin.  It is anticipated that the format of the meetings will generally
                   follow that used for Nebraska Wetlands Conservation Plans, which
                   includes Open House sessions, large group presentation, and small
                   group discussions. Relevant portions of the NDEQ strategic
                   monitoring plan will be presented with an explanation of how the
                   resulting data will be used for assessing water quality and prioritizing
                   management needs. This initial outreach will provide  stakeholders
                   with opportunities early in the basin planning process to submit
                   relevant information, identify potential gaps in the monitoring
                   strategy, participate in data collection where appropriate, or provide
                   other feedback.

Step 3.  Implement Strategic Monitoring Plan

                   The strategic monitoring plan for basinwide assessment will be
                   implemented following any modification resulting from feedback
                   received during  initial outreach activities.

                 ( 2  Public Outreach
                   7 Public Outreach
                                                                           APPENDIX B
                                                                                    YEAR 1
                                              1  Draft Strategic Monitoring Plan
                                              3 Implement Strategic Monitoring Plan
                                              4 Canvas for Information
                                              5 Analyze Information
                                              6 Prioritize Problems and Critical Issues
                                              8 Implement Updates to Strategic
                                                Monitoring Plan
                                              9 Problem Quantification
                                             11  Prepare Draft Basin Plan
                    Public Outreach   )	>-   12  Agency and Public Review
                                             13 Complete Final Basin Plan
                     Public Outreach   )	*   14 Basin Plan Implementation
                                            10  Develop Management Strategies        I

                                                                        APPENDIX B
Step 4. Canvas for Information
                    NDEQ will make direct contact with key agencies and other entities to
                    obtain additional relevant information for use in basin planning.  In
                    particular, data will be sought for characterizing the basin (e.g.,
                    hydrology,  land-use, population demographics, economic base,  etc.)
                    and for evaluating water quality.  Stakeholder information will also be
                    used where appropriate in the prioritization and management strategy
                    development process.
Step 5. Analyze Information
                    Initial analyses of basinwide monitoring data and supplemental
                    stakeholder information will focus on determining use support status,
                    identifying problems and areas of special ecological value, and
                    assessing information gaps.  Limitations in data  coverage should be
                    specified so that initial findings can be appropriately qualified. Some
                    quantification of problems may occur to clarify causes and sources,
                    estimate loading, and quantify assimilative capacity. Further analysis
                    and more detailed quantification of problems will continue for waters
                    that are prioritized in the next step.  Known gaps in field data will be
                    addressed during updates of the strategic monitoring plan.
Step 6. Prioritize Problems and Critical Issues
                    NDEQ will apply a standardized set of criteria and procedures to
                    prioritize waterbodies in need of management or additional
                    assessment so that resources can be targeted to address the
                    concerns in an efficient and effective manner.
Step 7. Continue Public Outreach
                    NDEQ will present potential stakeholders with a summary of the initial
                    water quality assessments and recommended management priorities.
                    Areas in need of further problem quantification will be identified.
                    NDEQ will attempt to match stakeholders to corresponding priority
                    waterbodies.  In some cases, "Focus Groups" may be formed among
                    stakeholders to help clarify matters. Stakeholder and Focus Groups
                    will form the basis for stakeholder involvement in the evaluation of
                    management options and development of basin management plans.
Step 8. Implement Updates to Strategic Monitoring Plan
                    Based on the results of initial assessment and prioritization,  along
                    with feedback from public outreach activities, NDEQ will update and
                    implement its strategic monitoring plan to gather data for further

                                                                        APPENDIX B
                   problem quantification.  This will include data for model development
                   or other tools necessary to evaluate management options.
Step 9. Problem Quantification
                   Additional problem quantification  will be performed where required to
                   establish the magnitude of a problem, determine assimilative capacity,
                   calculate loads for contributing sources of pollutants of concern, or
                   otherwise further assess the problem such that sufficient information
                   is available for management strategy development.  This  includes field
                   calibration of models and development of total maximum daily loads
Step 10.  Develop Management Strategies
                    NDEQ will work with other stakeholders to arrive at a consensus on
                    management goals,  such as specific waterbody segments to be
                    restored or protected. This will include loading reductions that should
                    be achieved, or the  amount of  habitat that needs restoring, etc.  Input
                    will also be solicited from stakeholders to establish feasible
                    combinations of point and nonpoint  source control measures and
                    management actions to achieve goals. Management options will be
                    evaluated via predictive  modeling, or by other methods where
                    appropriate, for their relative effectiveness at achieving environmental
                    objectives. Regulatory constraints and procedures will be considered,
                    and stakeholder consensus will be sought where voluntary efforts are
                    needed to meet environmental  objectives.  Selected management
                    strategies will  outline mechanisms for  implementing controls, time
                    frames, anticipated  costs, sources of funding, monitoring strategies,
                    compliance tracking and enforcement  methods, etc.
 Step 11.  Prepare Draft Basin Plan
                    NDEQ will prepare a draft basin plan which documents the results of
                    the basin planning process  including assessment, priorities, goals,
                    selected management alternatives, and the implementation  strategy.
 Step 12. Agency and Public Review
                     An internal review of the draft basin plan will be performed to ensure
                     that it is ready for public distribution. Upon agency approval, the plan
                     will be made available for public review and comment.  Outreach will
                     be provided to explain provisions and implications of the plan.

                                                                       APPENDIX B
Step 13. Complete Final Basin Plan
                   Modifications will be made to the plan, as necessary, based on
                   comments and input received through the review process, to
                   complete a final basin plan.

Step 14. Basin Plan Implementation

                   Each cycle ends with a basin plan implementation period.  The
                   implementation strategy outlined in the plan will be followed, taking
                   such steps as necessary to implement pollutant source controls, best
                   management practices, monitoring programs, enforcement  methods,
                   etc.  Activities occurring during this period will include public notice
                   and issuance of NPDES individual and basin general permits,
                   distribution of state revolving fund (SRF) loans to prioritized entities,
                   and allocation of 319 funds to prioritized NPS problem areas.  In
                   addition, implementation will include  an outreach component to
                   communicate the goals and selected  management strategies of the
                   final plan. Outreach will also be used to educate stakeholders on
                   implementation schedules, milestones, and where regulatory and
                   voluntary efforts are required to meet environmental objectives.

The final basin plan contains recommendations for follow-up basinwide assessment to
measure the degree of success from plan implementation  and to evaluate areas  that were
not assessed during the previous cycle.  After a specified  period of time for plan
implementation,  NDEQ will implement the updated strategic monitoring plan and the basin
management cycle will be repeated.

The basin management cycle will not be initiated in all basins at the same time for practical
reasons. Activities within the thirteen basins will be sequenced so that steps are
performed incrementally across the state. This helps to balance program workloads.
Focusing on the same steps  at one time in a small segment of the state creates a more
efficient and effective operating framework.

Table 1 shows the sequence and scheduling of steps for Nebraska's thirteen river basins.
The order in which river basins will be addressed is shown along the left hand column of
the table. Corresponding schedules for performance of each step of the basin management
cycle are shown to the right of the column of basins. Two lines of symbols are used for
each basin to better depict simultaneous activities (Note:  symbols are defined in the
legend at the bottom of the table).  The table shows how  steps are phased in across the
state over the first five-year  cycle from 1994 to 1998. Basinwide management activities
will be ongoing in all basins across the state by  1998, and basin management plans will be
implemented for all basins by the end of 2001.

Specific scheduling  patterns have been incorporated within the basin cycle. For instance,
the vast majority of field monitoring activities for NDEQ's  Water Quality Division are
performed between May and November for scientific reasons. Therefore, strategic

                                                                       APPENDIX B
monitoring plans will need to be finalized by the end of April each year so that actual
sample collection can begin in May.

Data analysis (A) and problem quantification (Q) are shown in the table under the months
of November through February following the first year of monitoring and information
collection  However, this does not mean that analysis and quantification are restricted to
that period.  Rather, this  is the period where data are screened and assessed for watershed
prioritization purposes.  It is recognized that analysis and quantification for purposes of
evaluating management options will continue  on in some prioritized watersheds up until
development of  management strategies and written plans.  This  is illustrated in the table by
the series of months with a Q following the Mq period.

Finally,  it should be noted that the length of time scheduled for follow-up problem
quantification and  management strategy development differs across basins that  are
grouped in the same year of the cycle. The times have been staggered so that only one
basin plan is being drafted at a time. For example, plan drafting will occur in July-August
of 1996 for the  Lower Platte whereas the basin plan for the Nemaha will be written in
November-December, 1996.  This same type  of pattern is repeated for each year of the
basin cycle.

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