&ER&
United States
Environmental Protection
Agency
Total Maximum Daily Loads
TMDL at a Glance
Middle Cuyahoga River TMDL
(approved January 2001)
www. epu. state, oh. us/dsw/tmdl/CuyuhoguKiverMiddleTMDL.uspx
a Factors causing impairment:
Warmwater aquatic life use impaired by low dissolved
oxygen resulting from three key factors: (1) excess
nutrients; (2) changes in the natural flow pattern of
the river; and (3) poor riverine habitat
Sources contributing to impairment:
Municipal wastewater treatment plant discharges,
dams, flow alteration
TMDL Implementation Restores Flow, Improves
Water Quality, and Preserves a Community's
Sense of History
The total maximum daily loads (TMDLs) for the Middle Cuyahoga River watershed
revealed that residents in the watershed had a tough choice to make if they wanted to
improve local water quality conditions. They could either (1) invest in expensive upgrades
to the local wastewater treatment plants to reduce the pollutants affecting dissolved
oxygen levels, even though the investment might not produce sufficient water quality
improvements to meet water quality standards, or (2) spend time and effort in
crafting a voluntary approach involving modification and removal of local dams
that would improve the river's natural flow, restore riverine habitat, allow for
fish passage, and increase dissolved oxygen (DO) levels. Wanting to avoid costly
upgrades that might not produce results, stakeholders in the Middle Cuyahoga
River watershed chose to cooperatively explore the innovative voluntary option
in a manner that could restore water quality, preserve local history, and create a
significant water feature. The result was the modification of the Kent Dam and
the removal of the Munroe Falls dam Implementation of this voluntary option
produced immediate, measurable water quality benefits. In addition to achieving
environmental goals, the TMDL implementation approach allowed stakeholders to
leverage financial resources and avoid costly wastewater treatment plant upgrades
and associated operation and maintenance costs. Efforts in the Middle Cuyahoga
River watershed also established important partnerships that would benefit future
TMDL efforts in other parts of the Cuyahoga River watershed.
Restoration options:
Reduce pollutant loadings from local wastewater
treatment plants or increase flows from a surface
impoundment and modify dams to increase natural
river characteristics
Stakeholder involvement:
Middle Cuyahoga Watershed Stakeholder Forum;
Kent Dam Advisory Council; local nongovernmental
organizations; local cities and counties; state and
federal agencies
Status of waternody:
Full attainment of Warmwater Habitat designated use
near the Kent Dam and anticipated full attainment
near the Munroe Falls Dam
Benefits to stakeholders:
Water quality, economic, historic preservation,
recreation, funding, partnerships
How are TMDLs at work in the Middle Cuyahoga River
watershed?
The TMDLs developed by the Ohio Environmental Protection Agency (EPA)
for the Middle Cuyahoga River watershed presented two possible options for
decreasing excessive nutrients and improving dissolved oxygen levels to restore
the biological integrity of the watershed. The TMDL report demonstrated that
while local wastewater treatment plants in the watershed are contributors to
water quality problems, solely focusing on more stringent permit limits for these
point sources would not result in attainment of water quality standards due to the
conditions in the watershed. Through the technical analysis, stakeholders were
provided with evidence to support the need for voluntary watershed efforts.
What is a total maximum daily load (TMDL)?
It is a study or analysis that calculates the maximum amount of a pollutant that a waterbody can receive and still meet
water quality standards. The TMDL establishes a pollutant budget and then allocates portions of the overall budget to
the pollutant's sources. For more information on TMDLs, visit EPA's website at www.epa.gov/owow/tmdl.
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Who were the participating stakeholders and key partners?
Ohio EPA was responsible for the development of the Middle Cuyahoga River watershed
TMDLs, with participation from key stakeholders and partners. Unlike TMDL
development, TMDL implementation is in the hands of local stakeholders and partners.
Local stakeholders that participated in TMDL development, and led subsequent
implementation activities, include residents and officials from the cities of Akron, Kent,
Massillon, Munroe Falls, and Ravenna; Portage and Summit, counties; the Summit
County Department of Environmental Services (DOES); the Northeast Ohio Four County
Regional Planning and Development Organization (NEFCO); and nongovernmental
organizations such as the Kent Environmental Council, the Kent Historical Society, the
Friends of the Crooked River, and American Whitewater. Key state partners included
the Ohio EPA, the Ohio Department of Natural Resources (ODNR), and the Ohio
Historic Preservation Office. Federal partners included the U.S. EPA, U.S. Army Corps of
Engineers, and U.S. Fish and Wildlife Service.
How did stakeholders participate in the TMDL process?
The overall TMDL process includes the following elements: Clean Water Act (CWA)
section 303(d) listing decisions, TMDL development, and TMDL implementation.
Each element of the TMDL process provided stakeholders with an opportunity to
express concerns and share information about the water quality problems in the Middle
Cuyahoga River with Ohio EPA and other key state and federal partners. A description of
each element of the TMDL process is provided below.
Section 303(d) listing decisions
If a waterbody does not meet water quality standards (i.e., numeric or narrative criteria)
for one or more pollutants, it goes on a state's CWA section 303(d) list of impaired
waterbodies and will require a TMDL for each pollutant contributing to the impairment.
Stakeholders have the opportunity to provide input during the CWA section 303(d) listing
process. Ohio EPA conducts water quality assessments for each watershed and creates
technical support documents (TSDs). The draft TSDs are available to interested parties
for review and comment. Once finalized, Ohio EPA issues a press release and makes the
final TSD available for public review.
For the Middle Cuyahoga River, the Ohio EPA asked the public to provide comments
during the development of the 1996 and 1998 CWA section 303(d) lists. Stakeholders
had the opportunity to provide feedback on the information contained in the list, such
as: 1) water bodies included or not included, 2) pollutant and other causes of failure to
fully support designated uses, 3) validity of data and information used, 4) submission of
additional data relevant to whether should be listed, and 5) the data interpretation rules
employed by the state. Stakeholders had participated in field surveys within the watershed
and Ohio EPA used the information provided in the technical analysis. The experiences
and concerns of these citizens complimented the data Ohio EPA collected.
TMDL development
The Ohio EPA initiated the TMDLs for Middle Cuyahoga River watershed to address
impairments related to excessive nutrients and low DO, as well as habitat and flow
alteration. Pollutants addressed by the TMDLs include carbonaceous biochemical oxygen
demand (CBOD), total nitrogen, and ammonia; these pollutants contribute to violations
of Ohio water quality standards for DO and biocriteria in the Middle Cuyahoga River
watershed. Ohio EPA used the DO water quality criteria to assess progress towards
conditions supportive of the warmwater habitat designated use. To directly determine
attainment of this designated use, Ohio EPA assesses the health offish and bug
communities in the watershed.
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Through the TMDL development process, Ohio EPA determined that local wastewater
treatment plants were the point sources contributing to the impairment. The analysis
indicated that no nonpoint sources made significant contributions contributed to the
impairment. However, in addition to the point sources, changes to the natural flow
of the river due to water consumption, dams, and impoundments also contributed
to the impairment. Based on conditions in the watershed and the sources and causes
of impairment, Ohio EPA selected the QUAL2E computer model to simulate DO,
temperature, phosphorus, CBOD, total nitrogen, and ammonia in the Middle Cuyahoga
River watershed. Information from the model helped Ohio EPA calculate the wasteload
allocations (WLAs) for the wastewater treatment plants for each pollutant.
The final TMDL report presents a tiered approach for calculating the WLAs, based
on two sets of assumptions regarding flow conditions in the watershed. Level 1 of the
tiered approach calculated TMDLs for CBOD, total nitrogen, and ammonia on the
basis of assumed changes in the flow of the Middle Cuyahoga River through voluntary
actions, including modification of the Kent and Munroe Falls dams. Ohio EPA predicted
attainment of water quality standards in the near-term under the Level 1 scenario. WLAs
under the Level 1 scenario would essentially allow the wastewater treatment plants to
preserve existing permit limits. (This scenario also required a minimum release from Lake
Rockwell, a water supply reservoir on the Cuyahoga River for the city of Akron, and minor
loading reductions from the wastewater treatment plants.)
If voluntary actions to change flow conditions did not take place within a specified time
frame, the TMDL report specified the Level 2 WLAs that Ohio EPA would enforce as
more stringent permit limits for wastewater treatment plants. The TMDL report stated,
however, that the more stringent permit limits generated under the Level 2 scenario would
not result in attainment of water quality standards. Even though hydromodifications and
habitat alteration are not pollutants, the TMDL analysis indicated that stakeholders would
have to voluntarily address this issue to attain water quality standards in the Middle
Cuyahoga River watershed.
The Ohio EPA worked with NEFCO and the Middle Cuyahoga Watershed Stakeholder
Forum, established in the 1990s as a way to foster regional cooperation, to ensure
stakeholder involvement in the TMDL process. Over the 17 month TMDL development
process, Ohio EPA facilitated public meetings to educate stakeholders and obtain their
input. Forum participants and the public had the opportunity to express their concerns
about conditions in the watershed and the TMDL process, as well as provide information
on the causes and sources of impairment.
TMDL implementation
Upon approval of the TMDL for the Middle Cuyahoga River in 2000, local stakeholders
initiated efforts to evaluate the recommendations put forth in the TMDL report and
develop a locally-led implementation strategy. Based on the costs associated with
wastewater treatment plant upgrades and the uncertainty over whether the investment
would produce environmental results, stakeholders opted to pursue the recommended
dam modification activities under the Level 1 scenario in the TMDL.
O Kent Dam. The Kent City Council convened the Kent Dam Advisory Council (KDAC),
which included many participants of the Forum. The 19 participants on the KDAC
evaluated the alternatives included in the final TMDL analysis and designed a plan
to modify the Kent Dam in a manner that would preserve the historic nature of the
structure and the overall historic district.
The implementation approach created by the KDAC, referred to as the Middle
Cuyahoga River Restoration Project, incorporated both water quality and cultural
preservation components. The project focused on preserving the arched dam
structure—one of the oldest arched dams in the country—while removing an old canal
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lock to allow the river to flow freely. Preserving the structure, as well as constructing
a waterfall, developing Heritage Park, and providing educational information on
the historical aspects of the area, were all requirements under the National Historic
Preservation Act (NHPA). In addition to the dam modification and Heritage Park, the
project also incorporated stream channel and streambank restoration activities.
O Munroe Falls Dam. The Summit County DOES led the Munroe Falls Dam
modification project. DOES staff presented three options to the public for their
consideration. The City of Munroe Falls wanted to maintain a significant water feature
in the river. Stakeholders selected an option that involved lowering the dam and
building a fish passage structure around the dam. Conditions at the site, however, led
to changes in the initial dam modification plans and resulted in removal of the dam.
Through this project, stakeholders discovered a rock ledge in the river that had been
hidden for over 100 years. Ultimately the project restored the natural flow of the river
and provided the City of Munroe Falls with the desired significant water feature.
By choosing to implement the TMDL through the voluntary dam modification and
removal projects, local stakeholders were eligible for grant funding that would not
have been available to finance wastewater treatment plant upgrades under the second
alternative. The project, completed in spring 2005, cost an estimated $5 million. Funding
sources included Ohio EPA section 319 grant, Ohio EPA's Clean Water Act State
Revolving Loan Fund's Water Resource Restoration Sponsor Program, the Clean Ohio
Fund, and supplemental environmental project (SEP) enforcement monies.
What is the current status of the Middle Cuyahoga River watershed
as a result of the TMDL process?
The Middle Cuyahoga River watershed is not yet in full attainment of water quality
standards; however, the voluntary dam modification and removal projects have resulted
in the anticipated chemical and physical water quality improvements, as indicated by
water samples and computer modeling. DO levels in the river are now consistent with the
state's water quality standards for this parameter. Also, the condition of the warmwater
aquatic live community in the stream also significantly improved. Prior to the project,
Ohio EPA assessed the diversity of the macroinvertebrate community (ICI), the fish
community using the Index of Biological Integrity (IBI) and Modified Index of Well Being
(Mlwb), and the physical habitat conditions using the Qualitative Habitat Evaluation
Index (QHEI). Scores from the initial assessment using the ICI, IBI, Mlwb, and the QHEI
indicated that the majority of the Middle Cuyahoga River did not meet the warmwater
habitat designated use prior to implementing the TMDL. The Ohio EPA assessed the
Middle Cuyahoga River from 2005 to 2007. Information from this assessment indicated
a 56 percent increase in IBI scores and a 57 percent increase in QHEI scores in Kent. The
river in the former Munroe Falls dam pool meets the QHEI and ICI criteria, but still has
a non attainment status for the fish indices. However, all the elements required for a full
recovery of aquatic communities to warmwater habitat standard were present, and the
river is expected to reach full attainment within the next few years. A full report of the
demonstrated improvement of the aquatic community is available at:
www.epa.ohio.gov/dsw/tmdl/CuyahogaRiverMiddleTMDL.aspx
How did local stakeholders benefit from the TMDL process?
The Middle Cuyahoga River Restoration Project produced the anticipated water quality
improvements, has restored portions of the river to full attainment, and is on its way to
meeting its warmwater habitat designated use in all segments. In addition to water quality
benefits, this successful TMDL implementation project has provided the cities of Kent and
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Munroe Falls, as well as other local stakeholders, with a wide range of additional benefits,
including:
O Leveraged financial resources. Local stakeholders, specifically communities with
wastewater treatment plants that would have required costly upgrades, were able
to avoid significant investments that were not guaranteed to result in attainment
of water quality standards. For example, the City of Kent alone avoided spending
nearly $5 million in wastewater treatment plant upgrades. Communities were able
to work together, along with state and federal agencies, to obtain funding for dam
modification and removal projects. The Kent Dam Water Quality Improvement
Project received more than $5 million in funding from state and local partners. Ohio
EPA's Clean Water Act State Revolving Loan Fund's Water Resource Restoration
Sponsor Program (WRRSP) provided $3.94 million. The Clean Ohio Fund contributed
$636,000. Ohio EPA provided $500,000 through a Clean Water Act (CWA) section
319 grant and ODNR provided $6,400 in additional grant funds. For the Munroe
Falls dam project, Summit County obtained more than $1.4 million from Ohio EPA's
Clean Water State Revolving Loan Fund's WRRSP. In addition, this project obtained
approximately $1 million in a CWA section 319 nonpoint source grant and $500,000
from supplemental enforcement environmental project monies.
O Historical preservation. The project preserved and restored the arched dam structure
dating back to the 1830s, but provided for a free-flowing river channel through removal
of an old canal lock east of the dam.
O Increased aesthetics and educational opportunities. Developing Heritage Park
in the drained dam pool to satisfy National Historic Preservation Act requirements
alsoaddressed concerns related to aesthetics. Interpretative signage in Heritage Park
educates visitors about the history of the area and associated environmental benefits of
the project.
O Effective local partnerships. The Middle Cuyahoga River Watershed Stakeholder
Forum and the Kent Dam Advisory Council set the stage for successful partnerships
necessary to address other water quality problems throughout the Cuyahoga River
watershed. Some of the participants in the Middle Cuyahoga River TMDL process also
participated in the TMDL processes for the Upper and Lower Cuyahoga River.
December 2009 • EPA841-F-09-002I
For more information on the Middle Cuyahoga River TMDL, contact
Steve Tuckerman, Ohio EPA, Northeast District Office, steve.tuckerman@epa.state.oh.us, (330) 963-1105
For more information on the Ohio TMDL Program, visit www.epa.ohio.gov/dsw/tmdl/index.aspx
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