Watershed-based NPDES permitting is an approach to developing NPDES permits for multiple point sources located within a
 defined geographic area (i.e., watershed boundaries). Through this approach, NPDES permitting authorities consider watershed
 goals and the impact of multiple pollutant sources and stressors, including nonpoint source contributions. This approach can
 encompass a wide variety of activities, from synchronizing permit issuance within a watershed to developing water-quality based
 effluent limits for a group of point sources, aimed at achieving new efficiencies and environmental results.

 Every watershed is different and requires customized solutions to protect and restore water quality. One size-fits all
 approaches go against this basic premise of watershed management. Watershed-based NPDES permitting recognizes the need
 for watershed-specific solutions and does not prescribe one approach. Instead, it provides several possible approaches to serve
 as examples and generate ideas. Examples of possible approaches include the following:

   • Watershed-Based Individual Permit-Multiple Permittees. This is a single NPDES permit that
     would cover multiple sources in the same watershed, or implement a Total Maximum Daily Load
     (TMDL) or watershed plan. Would allow several point sources within a watershed to apply for
     and obtain coverage under the same permit.

   • Watershed General Permits. This approach relies on
     general permitting and would be similar to many existing
     general permits except that the watershed boundary defines
     eligibility for coverage or applicability of certain conditions
     (e.g., monitoring).

   • Integrated Municipal Permits. This approach bundles all point
     source requirements for a municipality into a single NPDES
     permit. It may or may not reflect watershed boundaries.

 Recent studies of the nation's waters reveal that nearly half of the
 water bodies assessed are not meeting water quality standards,
 and  that point source discharges are a contributing factor in many
 of these impaired waters. Where conditions are right for this
 approach, watershed-based NPDES permitting may successfully
 address these remaining water quality problems and produce
 further water quality improvements. In addition to environmental
 results, other possible benefits of watershed-based permitting
 approaches may include:

   •Integration of other watershed protection programs under the
     Clean Water Act and the Safe Drinking Water Act

   •Targeted and maximized use of resources to achieve
     environmental results

   •Increased and coordinated public involvement in the
     permitting process

   •Cooperation and collaboration among point source dischargers
     and other key stakeholders within the watershed

   •Opportunities for water quality trading and other market-
     based strategies for meeting water quality standards.

                                   IS   WATERSHED-BASED
                                  PERMITTING    HAPPENING?
In the Tualatin River watershed, both TMDLs and
endangered species issues are primary concerns. Clean
Water Services is responsible for wastewater and surface
water management in urban Washington County, which
translates into  numerous permits  and requirements
under the NPDES program. Under a multi-year pilot
project, Clean Water Services is evaluating the technical,
stakeholder, regulatory and legal issues surrounding the
development of a watershed-based NPDES permitting
approach that will result in a permit that covers multiple
point sources. Two outcomes  of the pilot project are
an interim permit that will allow  development of a
watershed-based permitting framework and  a 5-year
project work plan to coordinate requirements under the
Clean Water Act, the Endangered Species Act, and the Safe
Water Act.
                                                         COLORADO: SELENIUM  STAKEHOLDERS
                                                         COLLECT DATA FOR  STANDARDS  IN THE
                                                         SOUTH PLATTE  RIVER
                                                         During the triennial review  process in 2000,  the  Colorado
                                                         Department  of  Public  Health and  Environment (CDPHE)
                                                         proposed lowering the chronic selenium standard. This lowered
                                                         standard would  make  compliance with NPDES water-quality
                                                         based effluent limits  challenging for point sources given current
                                                         technological limitations for selenium removal and nonpoint source
                                                         contributors. Conoco Inc. convened a stakeholder group of point
                                                                   sources that discharge to the  South Platte River and
                                                                   its tributaries to discuss potential impacts of changing
                                                                   the selenium standards within this watershed. Based
                                                                   on data presented by the Selenium Stakeholder group
                                                                   during the Triennial Review hearings, the state granted
                                                                   a three-year Temporary Modification for a portion
                                                                   of this watershed to allow for additional monitoring
                                                                   to better understand  the sources of selenium and
                                                                   determine site-specific selenium criteria. This study,
                                                                   now in its third year of implementation, has facilitated
                                                                   the collection of a large amount of quality data which
                                                         can be used to develop and implement TMDLs in the future at a
                                                         significant cost savings to the group.
                                                        CONNECTICUT: MULTIPLE POTWS
                                                        IN LONG ISLAND SOUND REDUCING
                                                        NITROGEN  UNDER ONE  PERMIT
                                                        In the summer, excessive nitrogen loading causes low
                                                        dissolved oxygen (DO) in  bottom waters of western
                                                                           Long Island Sound. The States
                                                                           of Connecticut  and New York
                                                                           have established a 2014 goal to
                                                                           reduce nitrogen loads and have
                                                                           formalized a nitrogen reduction
                                                                           program  through a  TMDL.
                                                                           To  help  achieve this  goal,
                                                                           the  Connecticut  Department
                                                                           of  Environmental Protection
                                                                           (CTDEP) developed and issued
                                                        an NPDES  permit addressing nitrogen discharges to
                                                        79 publicly-owned  treatment works (POTWs)  that
                                                        discharge at least 20 pounds of total nitrogen  (TN) per
                                                        day to Long Island Sound. Existing individual permits
                                                        held by the POTWs continue to regulate other pollutants
                                                        and protect against localized impacts. Reductions in TN
                                                        close to  the low DO impact zone in the Long Island
                                                        Sound are more "valuable" than TN reductions from
                                                        more distant sources in the Sound; this disparity in
                                                        credit value promotes trading through the  Nitrogen
                                                        Credit Exchange  program. The  ultimate measure of
                                                        success in this watershed-based permitting approach is
                                                        meeting, or  exceeding, the nitrogen reduction schedule
                                                        in the TMDL; as of 2002, the nitrogen reductions are
                                                        several years ahead of projections.
I'houi; Courtesy. NCUENK-DWQ.
                         RIVER COMPLIANCE ASSOCIATION
                         Nutrient impacts led to TMDLs  and the Neuse  River Basin Nutrient  Sensitive  Waters
                         Management Strategy. To meet the Strategy's 30 percent total nitrogen reduction goal, public
                         and private entities in the basin that hold individual NPDES permits formed the Neuse River
                         Compliance Association. The North Carolina Department of Environment and Natural
                         Resources (NCDENR) issued an individual watershed-based permit with multiple permittees,
                                        called a group compliance permit, to the members  of the Association.
                                        Dischargers participating in the Association keep their existing individual
                                        permits, but are subject to  the TN limits in the group compliance  permit.
                                        The TN limit in this permit is the sum of all TN loads for each of the
                                        Association members, established and allocated through the TMDL. If
                                        Association membership changes, the Association's TN allocation changes
                                        accordingly. The Association serves as the point of contact between the
                                        members and NCDENR and conducts activities for the  group such as
                                        reporting. The group compliance permit does not contain any monitoring
                                        requirements; members of the Association adhere  to the monitoring
                                        requirements contained in their existing individual permits.

Watershed-based NPDES permitting is gaining momentum and EPA is committed to accelerating this approach through a variety
of actions focused on education and technical assistance, as stated in the January 2003 Watershed-Based NPDES Permitting Policy
Statement. EPA has conducted activities such as compiling research and background information on watershed-based NPDES
permitting, identifying and analyzing existing examples of this approach, and creating case study fact sheets. In addition, EPA has
committed to developing guidance on implementation and technical issues surrounding watershed-based NPDES permitting.
Where there is an interest in using this approach, EPA can help to initiate efforts by acting as a facilitator or identifying
funding opportunities.

To date, EPA has generated several resources to educate stakeholders on the watershed-based NPDES permitting approach. EPAs
web site is the primary resource for obtaining information on this approach, including:

    •  Watershed-Based Permitting Under the NPDES Program: A Summary of Related Background Information.
       A compilation and summary of past research, policies, memos and case studies.

    •  Potential Partners in Promoting Watershed-Based Permitting: An Analysis of Watershed Organizations. An analysis
       of 29 watershed organizations to identify the various roles that they  can play in this permitting approach based on existing
       organizational goals and activities.

    •  Watershed-Based NPDES Permitting Policy Statement. Policy signed by Assistant Administrator for Water, G. Tracy
       Mehan III on January 7,2003, that demonstrates the Agency's significant level of support for this approach.

    •  Committing EPA's Water Program to Advancing the Watershed Approach. Memo from EPAs Assistant Administrator
       for Water, G. Tracy Mehan III on December 3,2002 that addresses steps the Office of Water will take to demonstrate
       renewed commitment to the watershed approach, including accelerating efforts to issue permits on a watershed-basis.

    •  Watershed-Based NPDES Permitting Case Studies. Series of fact sheets that present an overview of existing watershed-
       based NPDES permitting activities around the country.
Resources that EPA will make available in the near future include an implementation guidance manual, a technical guidance
manual, and training opportunities.
  The process used to generate NPDES permits under a watershed
  approach will vary from watershed to watershed. There are basic
  steps that stakeholders involved in the process can use as a starting
  point. Stakeholders should tailor this process to fit the needs of the

    Step One:    Select a watershed and determine boundaries.
    Step Two:    Identify stakeholders and facilitate their participation.
    Step Three:  Assess water quality conditions of the watershed.
                Collect and analyze data for permit development.
    Step Four:   Develop watershed-based permit conditions and
    Step Five:    Issue watershed-based permit(s).
    Step Six:     Measure and report progress.

  A wide variety of stakeholders can affect, and are affected by, watershed
  management decisions. As in any watershed effort, it is imperative
  to identify and involve stakeholders in watershed-based NPDES
  permitting early on in the process. Every step in the watershed-based
  NPDES permitting process contains an opportunity for stakeholders
  to participate! Stakeholders such as the NPDES permitting authority
  and point sources may initiate and facilitate the overall process. Other
  stakeholders, such as local watershed organizations and residents, may
  contribute data and information or provide input on the technical
  process. Every watershed-based permitting approach is different;
  therefore, the type of stakeholder involvement will vary.

                                                                   WHERE  CAN  I  FIND
                                                                   MORE  INFORMATION?

                                                                   For more information on watershed-based
                                                                   NPDES permitting, visit EPAs web site at

                                                                   May 2003
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