Watershed-Based Permitting — A Myth or Reality?by Sri Rangarajan, P.E., Ph.D.,
Abstract: The United States Environmental Protection Agency has promulgated the Total Maximum Daily Load process to achieve the goals of the Clean Water Act. The TMDL processis applied to water bodies in which water quality standards are not achieved for one or more water quality parameters (pollutants). Nationally, the EPA has listed more than 20,000 water bodies as impaired for supporting designated uses such as aquatic life propagation, contact recreation, and human health including special uses such as drinking water supply. This process establishes pollutant load reductions from individual point and non-point sources of pollution required to restore designated uses. The TMDL process becomes very complicated when the pollution sources include urban wet weather discharges such as combined sewer overflows (CSO), sanitary sewer overflows(SSO), and stormwater discharges. The pollutant loads from these sources are large but intermittent in nature. Many municipalities served by combined sewer systems have completed or are in the process of developing long-term control plans in accordance with the presumptive or demonstrative approaches outlined in the National CSO Control Policy. Similarly, the municipalities with separate sewers have been addressing the stormwater and SSO issues throughthe Phase I/II and CMOM programs. The challenge from a municipality's perspective is to establish pollution control plans that identify infrastructure requirements and management practice needs before major capital improvement programs can begin. Consequently, many municipalities have delayed implementation of the CSO controls identified in their LTCPs. Others have pursued pollution control programs limited to the achievement of high-priority objectives such as sensitive water bodies (e.g., bathing beaches) and sensitive or vulnerable populations (e.g., endangered species). One of the recent EPA initiatives is watershed-based permitting, which accounts for influences from all contributing point and non-point sources of pollution in a watershed in the World Environmental and Water Resources Congress 2008 Ahupua'a 2008 ASCE permitting process. This can be a successful mechanism for communities with wet weather discharges, however, it can be a myth or reality depending on the surrounding technical and policy considerations. In this paper, some of these considerations will be discussed with specific examples and technical approaches to support adoption of this permitting process that can help achieve the goals of the Clean Water Act sooner.
Subject Headings: Watersheds | Water pollution | Clean Water Act | Water quality | Combined sewers | Nonpoint pollution | Local government | Pollutants | Water-based recreation | North America | United States
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