Draft Cap Load Allocation Ideas, Criteria, Decision Rules, Supporting Information Needed and Clash Points Possible Equity Clash Points • Between tributary basins • Between states • Between developed vs. less developed regions/counties • Point sources vs. nonpoint sources • Urban areas vs. rural areas • Regions that have invested significantly in implementation actions vs. regions that don't have a similar implementation record • Growth potential vs. lack of growth potential • Reduction needed to for local water quality response vs. reduction needed for "downstream" water quality response • Upgrading WWTPs will remove extra capacity for additional flows Possible Allocation Approach Between Major Basins Define broad range of loading caps • Basinwide percent reduction scenarios • Tracer analyses: dissolved, particulate; equal load, proportional load Narrow down on basinwide loading caps for criteria attainment • Large regions of the Bay basin scenarios • Groups of tributary basins scenarios • Scenarios needed to define minimum load reductions by major tributary basin required to attain Bay criteria in upper tidal tributary reaches where water quality is only influenced by that tributary basin's loads Define "inside" vs. "outside" basin load influences on target basin's tidal water quality • Series of significant loading reductions within individual tributary basins with all other basins held at 2000 Progress scenarios • Series of individual tributary basins held at 2000 Progress with significant reductions consistently across other basins scenarios Allocate overall cap to the nine major basins • Scenarios focused on helping define future implementation capacity, relative delivered loads, relative cost effectiveness • Series of management scenarios by tributary basins testing feasibility/effectiveness of draft assigned cap allocations Allocate basin caps between jurisdictions • Series of scenarios testing different allocations between jurisdictions • Series of scenarios confirming the draft final and final set of basin loading caps allocation between jurisdictions Support individual state efforts to further allocate the loading caps to tributary strategy sub- basins • Scenarios run at the request of the individual jurisdictions ------- Possible Decision Rules/Criteria for Allocating Between Major Basins • Minimum allocation required to attain Bay criteria within those tidal waters whose water quality conditions are solely influenced by loads within individual major basins • Load reductions do not cause exceedences of established economic and social impact thresholds (defined through the UAA and existing EPA guidance) • Relative difference between progress achieved to date and maximum possible implementation opportunities relative of existing technologies • Relative cost effectiveness of reductions normalized on the basis of load delivered to tidal waters Possible Decision Rules/Criteria for Allocating Between Jurisdictions • Establish a set of "minimum allocation" to "maximum feasible" loading reduction windows for each of the jurisdiction/basins with minimum allocation based on load reductions needed to attain Bay criteria in the upper tidal tributaries (tidal fresh and oligohaline reaches) and the Susquehanna contribution load reduction necessary to attain Bay criteria in the mainstem Bay and lower tidal tributaries beyond what MD and VA can do. • Run a 2010 scenario with no BMPs/no WWTP upgrades, determine total controllable portion of loads, and then use this information to credit jurisdiction's basin using each jurisdiction implementation-based reduction progress over the past 15 years as a portion of total controllable. Possible Information Needed to Support Allocations • Total nutrient/sediment load delivered from each jurisdiction/basin • Relative delivery ratios from each jurisdiction/basin • Nutrient/sediment yield from each jurisdiction/basin • Current implementation levels by practice, WWTP treatment level relative to future implementation capacity for each jurisdiction/basin • Tracer analysis information for dissolved and particulate tracers based on equal load and proportional to actual load Listing of Possible Allocation Rules. Information Needs, etc. • Equal percent load reductions • Equal raw load reductions • Equal cost per pound reductions • Minimize total cost to watershed • Minimize total load reduction to achieve criteria • Local water quality benefits • Local economic benefit re. increased recreational uses, taxes (re. property values, sales of consumer goods, tourism) • Local TMDLs • Cost effectiveness • Use relative allocation proportions given the existing loading caps and how the tributary strategies allocation responsibilities by sources/region ------- |