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Topic 1: The Watershed Approach

2010 March 16

EPA has long focused on identifying impaired waters and restoring their water quality.  Recently, EPA has begun efforts on the protection and conservation of healthy, functioning watersheds, which provide the ecological support system essential for achieving water quality restoration. Our challenge is to weave a range of voluntary programs, regulations, and strategies into an effective method of protecting whole geographically based drainage areas.

•    If you have experience with protecting watersheds, what has worked and what hasn’t?

•    How can we protect and improve watersheds given the challenges of various sources of pollution?

•    What examples of effective practices and strategies can be “scaled up” to State and national levels for greater effectiveness and broader use?

For more detail about why and how conference participants will be approaching this topic, please see the Discussion Document at right.

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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104 Responses
  1. March 23, 2010

    Retired College Prof Volunteering on 319 Grants in East Central Indiana
    region. CAFOs ( 50 new CAFOs in our area) regulated as far as site of production is concerned, but not as manure leaves site for land application. No regulation. Being applied on frozen ground and during high runoff peroids without any incorportation in to soil. Results every 12 digit HUC has E. coli above limits most of time.
    We can sample above and below application zone and treat as point source. No longer dealing with nonpoint pollution in rural areas. Dozens of sources equal to small towns now being created. EPA must change attitude about these potential sources. No regulation in Indiana. IDEM
    Water Quality Division only becomes involved with a split event. Division of Land Management Division solely responsible for CAFOs and they don’t know what they are doing. The State Government does not want to find what is going on.

  2. March 22, 2010

    Watershed-scale management is meaningless if it doesn’t engage citizens, and for the most part, it doesn’t. There are several reasons for this: (1) most government agencies are guided by a top-down regulatory approach, rather than a collaborative approach: (2) the goals of EPA and corresponding state agencies are mainly a few targeted pollutants that may or may not matter to citizens in the watershed (how does one convince a farmer in MN to reduce fertilizer input to save the Gulf of Mexico, when his main focus is his/her own economic survival?) Often this means working with citizens on the problems in their watershed (in the case of the farmer, improving his/her economic condition); (3) the TMDL approach is heavily model based, whereas an adaptive management approach might be more useful; (4) agencies often have barriers to working with citizens (e.g., work rules that disallow evening meetings – when working citizens can meet: (5) many less formal watershed groups cannot take advantage of funding because they are not 503c groups; agencies could help by serving as financial agents; (6) pollution agencies aren’t trained (generally) to communicate with citizens (naming a program “TMDL” is probably the worst possible way to communicate the idea of a “pollution reduction plan” (it takes me two full lectures in a graduate water policy class to explain the TMDL concept); (7) most water quality data is either unavailable to citizens who lack database management tools (which is to say, nearly all of them) or incomprehensible (it need not be).

    Nonpoint source pollution is, to a very large extent, pollution coming from private lands, either households or farms. It is nearly impossible to regulate (except possibly for animal ag), so it is imperative to engage citizens in a meaningful way.

    So far we haven’t, and have had little success at controlling NPS pollution.

  3. March 22, 2010

    The waterways of Tennessee, Alabama, Appalachia, and all of the 25 coal mining states are under attack from the coal industry. While I type this mountains are being blown to bits by the coal mining industry, coal fly ash is pouring into the Emory, Clinch, and Tennessee Rivers, and coal burning power plants are dumping millions and possibly billions of pounds of pollution onto and into the land, air, and water. With the latter the pollution dumped into the air and onto the land finds its way into the water at some point.
    I want the EPA to start doing its job by enforcing the laws of the land and regulating the industries that are out of control throughout coal country. Right now there are untold amounts of heavy metals suspended in water being discharged through sediment ponds through NPDES permit points which amount to unpermitted discharges. All of these metals are providing a heavy load and undue burden on the critters and cleanliness of the water. I am asking that EPA hire more personell to get out into the field and test the water coming from these coal mines for the entire spectrum of heavy metals that have ever been associated with coal in this country. I am also asking that EPA take over control of the water monitoring of coal mines that is occurring right now because the states have dropped the ball on this monitoring by turning it over to the coal industry, in effect allowing the polluters to police themeselves or by requiring the coal industry to only test for a few metals or no metals at all. I am also concerned with the fact that the NPDES limits that are set for water monitoring don’t apply during rain fall events. This means that an untold amount of sediment is being flushed into our waterways during rain events. What is point in even having sediment ponds if the companies aren’t required to maintain the effluent limits during rain events? This is a crime of geologic and hydrologic scale.
    I think that EPA needs to step up the plate and declare coal fly ash a hazardous waste. This is a critical step in ensuring that this most dangerous of substances is handled in a responsible manner and instead of like solid waste (household garbage) such as what is happening here in Tennessee.
    What I don’t understand is with the TVA Coal Ash Disaster why EPA is so concerned with protecting the communities of Roane County and Swan Pond in Tennessee yet has turned a blind eye to the destruction of the Environmental Justice Community of Union Town in Perry County, Alabama.

    In fact I am using this comment to file an official complaint with the EPA about the lack of proper regulation and protection of the community of Union Town in Perry County, Alabama. I am filing a complaint to let you know that Arrowhead Landfill is not using Flexterra to control the airborne coal fly ash dust coming from the uncovered landfill like EPA forced TVA to do in Roane County, TN. There is not adequate wheel wahsing of trucks and all vehciles leaving the landfill area which has led to coal fly ash being tracked into the surrounding community. I am also filing a complaint that the landfill is dumping the leacheate (landfill juice ) into the ditches surrounding the landfill and right next to people’s homes. This is injustice at its worst and EPA has taken an active role in locating this landfill for TVA to dump the coal fly ash from Roane County, Tennessee.
    I would like to speak with an represenative of EPA about these complaints so that we can resolve them in a timely manner and provide some relief for the impacted residents.
    Thank you, matt landon

  4. March 22, 2010

    Obviously the best practice for improving water quality is to strictly control both point and non-point sources of pollution and limit the amount of toxins and chemicals that don’t belong in our rivers.

    The second most important practice is the removal of obsolete dams that block water passage. Dam ponds change local environmental conditions, defeat the survival of indigenous plants, animals and insects. Dams also greatly contribute to thermal pollution of water bodies and this degrades water quality downstream.

  5. March 22, 2010

    Soil conservation efforts have been “on the ground” for decades, yet nutrients (and soil) continue to leave the field. Voluntary efforts coupled with cost-share dollars are obviously not the solution. Why do we provide funds to install GMPs for those creating problems and then allow them to back out of their contract if they decide they don’t like it.

    How about rewarding those who are managing their production well. A straight out financial bonus for exemplary behavior, that continues only as long as the behavior continues or is improved. This has been proposed before, but never seems to be put into practice.

    Two examples of success, both based on people:

    A farmer happened to be caught out in a fast-driving rain. He observed the water running off from his field and noted the bank sluffing off and being carried away. That was an “aha” moment, when he truly realized that failing to maintain terraces was allowing his fields to lose topsoil and effectively become smaller. That meant less ground for cropping… less income. He began implementing GMPs.

    A small city surrounded by ranching and farming had no stormwater management. A passionate and knowledgable woman hired as a watershed specialist by the Extension Service, began public outreach programs that targeted people of all ages in the entire watershed. She organized events for families that taught them about stormwater management. She wrote grants to support monitoring of stormwater flows by students, then used the data collected to prioritize areas causing problems. She persisted with the City Council to collaborate in addressing these areas.

    People are the key to success in any endeavour.

  6. March 22, 2010

    Interest is growing in creating monitoring solutions for entire water resources – rivers, bays, catchments and so on. These work by integrating 3rd party sensors, existing data feeds such as those from USGS and EPA, and water agencies’ SCADA systems into modeling, analytics and visualization tools to create “collaboration platforms” for all of the stakeholders to that water resource. The water resource is given, in effect, its own sensing and systems infrastructure. The idea is to enable all the stakeholders to share “a single version of the truth” such that the quality of decision-making processes is improved. In so doing, you don’t remove the politics, but you do elevate the quality of the debate.

    In the course of this work a number of things have become evident:

    1) Data may or may not be available to manage water quality and water resources, but where it does exist it is likely to be fragmented, incompatible, and on the wrong scale for the decisions to be made. Tools are needed to enable the required level of integration between the multiple sources that exist, supported with additional sensing and data collection to “fill in the gaps”. This in turn requires definition of models and frameworks for applying IT to water management and also a sustained long-term investment in areas such as standards.

    2) There is much work at the federal/regulatory and university levels to collect and integrate data, but the voice of local operational water managers in water agencies is missing from these efforts. Water resources need to be managed day to day with the same (or compatible) data that is used at the federal level to monitor their health, drawing on the latest university work.

    3) Too much academic research on water issues seems to look backwards and/or to be content just to test hypotheses and publish papers without applying the learnings from that activity to day-to-day management of water resources. A more profitable line of approach would be to create scientifically valid models of the behavior of specific water resources that can be used to drive day-to-day operational decisions.

    4) We don’t yet fully know what we don’t know. For example, one can anticipate that there will be needs to monitor emerging contaminants such as decomposition byproducts from pharmaceuticals – but these byproducts are only now becoming apparent, and sensors that can monitor them in situ do not yet exist. We expect that over time, they will come to exist and that water managers will want to add the capabilities they offer to their monitoring activities. One of the key issues when designing collaboration platforms is therefore the capability of adding additional devices for purposes that cannot be foreseen today, but at very low marginal cost, given that the infrastructure to support them will already be in place.

    5) Related to the previous point, there needs to be a sustained effort to create and apply sensing technologies to water resource management, for example with emerging contaminants as just stated, pathogens and so on. The goal needs to be to create devices that can operate on riverbanks for extended periods, unattended – but at present too much is dependent on lab tests in part because the technologies needed don’t yet exist, or if they do exist, they are not sufficiently robust. Lab tests, while very accurate, do not provide the same kind of “truth” as continuous, even if less accurate, time-series readings from in-situ devices.
    6) While not everything needs to be real-time, there is more and more awareness of the value of real-time data, and the concept of real term inference generation from running models on-line to the decision process and in real time. In this way, advanced warning of preconditions for algal blooms, flow and temperature fluctuations, and so on, will be available along with the chance in some cases to take preventive action.

    6) It is not just about data. It’s also about models, applications and visualization tools to make use of that data. This tends to get forgotten in many discussions on water management.

    I hope these comments based on my experience of using technology to create “collaboration platforms’ to manage water resources are helpful. I’d be pleased to elaborate further if there is interest.

    Peter Williams

  7. Mary Munn permalink
    March 22, 2010

    Please halt winter land application of biosolids and manure. It causes early snow melt and it JUST RUNS OFF of the frozen ground.

    It should be tilled or drilled otherwise the net result is runoff.

  8. March 22, 2010

    After 25 years of protecting and restoring the Clark Fork Watershed in western Montana and northern Idaho, the Clark Fork Coalition offers these suggestions:

    – Ensure states establish–and enforce–numeric nutrient criteria for waterways. Set-up frameworks for complementary water pollution mitigation banks to trade “water pollution credits” so that the criteria can be met.

    – Invest in dam removals, repairs, and irrigation infrastructure improvements only if coupled with restoration projects that restore flow and function to the stream, lake, or river where the infrastructure is improved.

    – Create federal tax incentives/credits for landowners who transfer water rights from consumptive (irrigation) use to leave more water in streams and rivers.

    – Provide low- or no-interest loans to municipalities for water and wastewater system improvements if they have growth policies and rules that promote water quality protections and efficient land use.

    – Invest in education and check stations in partnership with states and local governments to prevent the spread of aquatic invasive species, like zebra mussels.

  9. March 20, 2010

    If we’re so interested in keeping our waters pristine why is DEP always running short handed. We should put whatever tax we need on drilling so that DEP has all the people they need to stay on top of the drillers. We seem to cut people in DEP just when we need them the most. As far as treating the frac water we have the technology to treat the water all the way back to where we could drink it so why should we settle for anything less??

  10. March 20, 2010

    In our area nothing seems to garner much involvement. The area of SW Missouri is rural in nature and frankly backward.
    I would advocate that all WWTP in a watershed get on a same date basis for permit renewal. New technology and methods would be addressed for that watershed and the receiving watershed. All cities would be on the same page and be brought up to standards at the same time. This would result in demonstable results when retrofit is completed. The permits would start tomorrow. The five year period starting immediately. New restrictions, methods of compliance and other factors would be metted out. This would give the WWTP five years to get in compliance before the next permit would be issued. All would be on same time line and could possibly lower costs when a company knows that all cities in the local area are going to need essentially the same upgrades or construction and thus assure them of a longer term period of employment and multiple purchases of equipment.

    Corporate farming is ruining this area of the state and the waters that flow through it and to neighbor states. We need to strongly oversee litter(manure) deposition and its movement from state to state. At this time it is not applied in Arkansas and thus is moved to Missouri with no or very little oversight. Missouri counties receiving it are already overloaded and are getting illegal litter from a neighboring state. It goes on and on like that. Missouri moves it to Kansas and Oklahoma is dumping it into both Kansas and Missouri. The DNR cannot or will not over see this movement and the Feds have no possible way of taking care of it.

  11. March 20, 2010

    I suggest that prevention and education are also important pieces of the watershed preservation equation. Prevention is often a more cost effective and more efficient tool than enforcing regulatory prohibitions.

    The recreational waters industries are principal stakeholders in the preservation of the watershed because of the economic impacts to their interests.

    It is important to work with recreational boaters and marinas to educate these groups on the proper disposal of toxic chemicals used in boat cleaning and the proper techniques of fueling to prevent accidental spillage into waterways.

    Recreation boaters and fishermen can also be a significant source of unintended spreading of Invasive Aquatic Nuisance Species. These species can overcome native indigenous species, deprive waterways of oxygen supplies and introduce excessive amounts of algae producing nutrients into the waterways.

    The US Wildlife and Fisheries Service have an initiative which is endorsed by the US Coast Guard known as the “Stop Aquatic Hitchhikers”. Stop Aquatic Hitchhikers is an educational outreach program aimed teaching techniques for the preventing the spread of aquatic nuisance species. Stop Aquatic Hitchhikers compliments the US Coast Guard’s “Sea Partners” program which has similar goals but is targeted towards prevention of unintentional discharges of toxic chemicals into the waterways.

    Both of these programs invite partnerships with other groups with similar goals of adopting a holistic approach to the prevention of damage to the watershed.

  12. March 20, 2010

    Several years ago the New England Environmental Business Council was invited to meet with senior staff at EPA Region 1 to explore how to implement the watershed agenda.

    The expectation was that we would somehow assemble an educational strategy for the region. Contrary to expectation we began to suggest that the root cause of the dilemma was not one of education but rather one of governance. Many of that same group, which includes traditional engineers, Bio-engineering professionals, community advocates an expert in collaborative design who is affiliated with the University of Massachusetts and a few others continue to informally work on the question that was posed to us.

    The following is informed by my participation in this and other groups as well as my professional interests and civic interests in economic development.


    We have a window of opportunity in which we can create and institutional structure through which we can realize the watershed agenda by leveraging it into into job and capital formation.

    At a time when Job formation is critical for industries like construction, engineering and the plumbing and electrical trades, when we are looking for ways to stimulate secure bank lending and when the EPA is searching for ways to advance the watershed agenda, converting existing septic systems to distributed sewer within the context of water resource management districts is economically compelling and could begin within months instead of years in most states.

    Once you have the formation of water resource management districts you have an architecture for continuous improvement and the measuring of results that you need to realize integrated water resource and watershed management within the context of climate change.

    WHY DO IT?


    A million septic systems converted to distributed sewer at $10,000 per home would generate about $10 billion in economic activity and 100,000 jobs. The Cadmus Group’s study for the 2008 Conference of Mayors indicates that water and wastewater infrastructure can have a multiplier affect as high as 6.38 on GDP and in 2.38 on job creation.

    There were 22 million septic systems recorded on the 1980 census. The 1986 EPA report to the Congress recorded that forty-four states consider septic systems among the highest polluters of groundwater and nine states listed them as the most significant source of pollution. Other reports from that era, when onsite systems were considered a temporary solution awaiting central sewer, suggest their average useful life for those built in the 50s and 60s was between 10 and 15 years and that they should not be deployed in densities greater than 1 home per 16 acres or about 40 per square mile. Currently, Freddie Mac assumes a 15 to 25 year useful life for a septic system for purposes of property valuation.


    There were 25 million Septic systems recorded on the 1990 census. In a 2005 progress document Ben Grumbles (Asst EPA Administrator for the Office of Water acknowledged: “Septic systems are the second greatest threat to groundwater quality (as
    viewed by State water quality agencies)
    There is currently limited information to document health and water quality problems
    resulting from poorly designed, operated and maintained systems, partly due to their
    widely distributed nature. The amount of impact to groundwater and surface water from sub-surface dispersal or surface-discharging decentralized systems is generally
    unknown. These impacts are currently being investigated by EPA.”


    Since the mid 1990’s with the focus on nonpoint pollution and the watershed agenda, the emergence of integrated water resource management and more recently the focus on climate change the reductions in carbon, nutrient and water footprints and wastewater to resource and reuse strategies, it is increasingly apparent that we can not achieve these policy objectives without a distributed approach to infrastructure.

    The realization of this potential is severely compromised by program structures that are over 40 years old and reflect a time when energy was inexpensive, the fate of nutrients was just beginning to be understood and climate change and sustainable principles were not even considered.

    Public policy has recognized this since the mid 1990s. It is best summarized by G Tracy Mehan (Assistant EPA Director for the office of Water) in his presentation to the Environmental Economics Advisory Committee on November 30, 2001, “Building on Success – Going Beyond Regulation”,
    • “Times have changed dramatically since the existing regulatory framework was put in place”.
    • “Point source controls alone are not capable of achieving or maintaining ambient environmental standards.”
    • “The assimilative capacity of our environment is limited and the technological and economic limitations of our existing regulatory framework are at hand.”
    • “The remaining water pollution problems are significantly more complex when compared with the problems that we have already addressed.”
    • “Complex problems require innovative solutions and entail a change in paradigm.”
    In a later statement he urged; “Failure to fully incorporate the watershed approach into program implementation will result in failure to achieve our environmental objectives in many of our nation’s waters.”


    Among the most dramatic expressions of this systemic failure is that despite the fact that “septic systems are the second greatest threat to groundwater quality (as viewed by State water quality agencies)” and despite the fact that they were considered a temporary solution, they now serve 25% of the population and about a third of new construction.

    These are serious times and this is a serious possibility. I think it is particularly compelling because the Obama Administration understands the essential nature of “systemic failure” and what to do about it. His language about how to resolve systemic failures in national security reflects a precise understanding of “predictive network -centric intelligence”. Moreover, the military model of network-centric battle field warfare where the battlefield instead of the preferred technology platform defines the skills, the technologies, the processes and the organizational structures through which the battlefield may be most efficiently engaged is a performance based and context sensitive design model that would serve the watershed agenda. It is a model that needs an adaptive approach to infrastructure made possible through a distributed approach.


    A utility in one of the fastest growing counties in the country in 2007 is designing a treatment plant that in the current economic climate it is not expecting to build. Responding to scattered commercial demand for development, the Executive Director asked “What can you teach me about decentralized wastewater treatment”.

    He was in pursuit of “distributed sewer”. More than this, however, he was in pursuit of an approach to infrastructure that placed the supply of his services in response to instead of in anticipation of demand.

    Open almost any comprehensive wastewater management plan and you will find a “needs assessment”. It may include hydraulically or organically overloaded central systems, demand for access by other municipal partners, aging septic systems, TMDL compliance and a host of other local issues. It is almost never a perfect balance of supply and demand.

    The dilemma is that under the centralized approach resolving one issue must wait for the provision of one prescribed and essentially dictated outcome Often pent up behind this dictated and delayed single source solution is the inventive energy and wealth creating capacity of the American economy. We need an approach to infrastructure that can be an adaptive interface between human communities and the natural systems on which they depend. We also need an infrastructure that will release the economic capacity that lies dormant beneath traditional programmatic structures and predetermined outcomes

    Decisions that once made sense are now having vast unforeseen and unpredictable consequences. It is true in energy and transportation. It is also true for water.

    Among the most important opportunities offered by a distributed approach to sewer are:
    • There can be a much more efficient and cost effective alignment between the demand for infrastructure and its supply and
    • It can supply highly effective and reliable treatment and diminish both the capital costs and the high energy life cycle costs of collection.


    Onsite wastewater treatment, which includes long obsolete cesspools, septic systems and alternative treatment units (ATU) at the residential level as well as small clustered and commercial treatment systems under the Health codes, have a set of common problems that are detrimental to property values the realization of environmental standards and results as well as economic development.
    • The costs of replacement and management are excessive
    • The codes under which they are installed impose restriction on use and development.
    • The performance standards with respect to integrated water resource and watershed management are compromised
    • The structure within which they are permitted does not anticipate watershed TMDL compliance, effective reuse water, water footprinting or climate change.

    There is little hope of improving this situation because there is nothing in the Public Health mandate or mission to promote management. Aware of this the EPA developed a voluntary protocol for Responsible Management Entities (RME), however few have been created and none have the capacities to aggregate participation, raise funds, assess fees and establish trusted and responsible management that are inherent in sewer ordinances.

    The following are representations of the potential economic advantages inherent in distributed sewer. They were developed based on the market conditions generally found in eastern Massachusetts. My pricing reflects pricing I have seen from the work of Teal Ltd, Northwest Cascade and others.

    The first looks at property values using estimates I derived from a discussion with a selectman from the town of Dennis on the Cape. He agreed a repair could cost in the range of $30,000 and he conceded a 7.5% increase in property value could be expected with municipal sewer services.


    Home value $350,000 $350,000
    Market decline -$ 52,000 -$ 52,000
    Market value $298,000 $298,000
    Septic repair -$ 30,000
    Distributed sewer $ 29800
    Net difference in value $ 268,000 $ 327,800

    Difference $59,800

    In this model we assume the property value was $350,000 before the economic downturn which projects a decline of $52000 leaving a market value $298,000.

    If a septic systems or cesspool must be replaced the projected cost is 30,000 and it is a direct burden on the homeowner.

    If the homeowner upgrades to municipal infrastructure the upgrade cost is attached to the property and paid over 30 years. We have assumed the property has increased in value by 7.5 % as a result of the conversion to municipal sewer services.

    The difference to the property owner is $59,800

    In the following two illustrations we project three estimates of the cost per home of distributed sewer based on a 30 home cluster financed over 30 years at a rate of 3% for <5mg/l Total Nitrogen. We assume 30 homes financed for 30 years at municipal interest rates of 3%

    Price $20,000 $18,000 $16,000
    Month $84 $76 $67
    Annual $1012 $911 $809
    O+M $133 $133 $133
    Total $1145 $ 1044 $942

    This system seeks to take advantage of economies of scale to achieve compliance with performance standards higher than those of most wastewater treatment plants while eliminating the capital and life cycle costs of traditional collection systems.
    I know it is not 3 mg/l TN but it is affordable.

    The final illustration plots the $18,000 cost figure and maintenance and monitoring on an annual basis with the application of the Massachusetts income tax credit. Note that on a cash flow basis the impact on the property owner does not occur until the 6th year of the program.


    1 $1500 $1044 $456
    2 $1500 $1044 $913
    3 $1500 $1044 $1369
    4 $1500 $1044 $1825
    5 $1044 $782
    6 $1044 -$262

    Even if you do all this in Massachusetts you are forced to do it in clusters of just less than 10,000 GPD and just less than 40,000 GPD because of O and M mandates in the codes.


    What stands between an affordable infrastructure that could achieve integrated water resource and watershed management, prepare water resource management for climate change and pay for itself and its implementation are two things:
    • Systemic inconsistencies that resist being reconciled and
    • Institutional and programmatic structures that will not take responsibilities for the economic environmental and social consequences of their costs.



    Ask city and county managers what they worry about the most and they will tell you;
    • Water quality and supply
    • Community preservation and quality of life
    • Economic development
    • Revenue

    This is surprisingly similar to the “triple bottom line” of sustainability;
    • ecological integrity
    • social equity
    • economic reality

    Couple this with the principles of reducing the carbon, nutrient and water footprints and you have the elements for a planning process that will adapt infrastructure to community instead of the other way around.

    This is a network-centric or context- centric or customized design instead of a platform centric approach to planning. Distributed wastewater management enables the context as it presents itself to define the technologies, the processes, the skills and the organizational structures that will deliver the best available outcome instead of the best available technology.

    The convergence of context sensitive planning and design, the ability to significantly reduce the costs of collection and to more effectively align demand and supply provides opportunities for infrastructure far beyond those offered by “traditional sewer” and our “existing regulatory framework”.

    That we have not been able to release these capacities is leaving water policy in the twentieth century while energy, transportation and other major infrastructures are being re-structured for the twenty-first.


    Water needs to have the support of enabling institutions not policing institutions. The EPA has rightfully transferred responsibility for water to the states and local responsibility but states have not had the political will to assume responsibility for the watershed agenda. More-over existing institutions and their flows of funds do not support the creation of such institutions. Change the structure, change the incentives and you will get a different outcome.

    Create incentives for water resource management districts to adopt the sewer ordinances. This allows for the capacities to aggregate participation, raise funds, assess fees and establish trusted and responsible management. It also provides freedom for property owners to develop their property without the restrictions imposed by environmental health and similar codes.


    Allow for wastewater management to be designed built owned and operated by private, public and public private partnerships just the way other utilities are.


    Stimulate the formation of water resource management districts through a portfolio of incentives including but not limited to “limited liability.”

    There is a predisposition to centralization in law, the codes and popular opinion that sewer is only central and that it is too expensive to be done any other way than with grants. Sewer can be achieved on a distributed basis efficiently and reasonably. Fairhaven, Massachusetts quietly worked out the transition between the public health and its sewer authority over 10 years ago.

    On a distributed basis sewers can be smaller and much less capital intensive so ike other utilities it can be easily scaled and considered on a private or public/ private partnerships as well as public basis.

    My thoughts on how to do this include:

    • Use the capacity in most states to establish special purpose districts.

    • Provide incentive so that the special purpose districts adopt the model desired for integrated water resource management ant he watershed agenda.

    • Recognize that these districts may be of any size so long as they meet or exceed existing and future performance standards for public health, watershed and water quality compliance.

    • Allow them to be structured on a private, public / private and public basis etc so that you can stimulate a cross section of activity.

    • Stimulate the public sector efforts with betterments and long term low interest loans, reverse mortgages etc.

    • Stimulate homeowner interest by allowing income tax credits and loan guarantees but only for participation with others in substantial enough numbers to ensure operations maintenance and monitoring and performance standards.

    • Stimulate private investment in the utility model with investment tax credits and accelerated depreciation.

    • Allow public private partnerships to use a mix across the spectrum.

    • This having been done set a deadline for the replacement of septic systems 25 years or older and a mandate that they be upgraded o performance based clusters.

    • Commercial, institutional and residential clusters should be upgraded and meet at least secondary treatment or reduced nutrient standards. They should be encouraged to assimilate smaller clusters hat may be in the vicinity. Accellerated depreciation may be a way to encourage this.

    • There is little reason for flows under 40,000 to 50,000 gallons per day to be rigorously scrutinized. This can be based on a self certification basis with engineered designs that must meet performance standards and engineers licenses and the legal system should be sufficient to ensure compliance. Existing regulatory structures should receive reports be paid for their expertise in solving problems and police compliance as they currently do.

    The idea has been not to force anything on an existing locality, but rather to impose a mandate on dealing with a significant contributor to ground water pollution in a forceful way and to simply load the incentives to create water resource management districts in the early years with declining incentives in the outer years in order to stimulate immediate activity.

    Once you have the formation of water resource management districts you have an architecture for continuous improvement and the measuring of results that you need to realize integrated water resource and watershed management.


    We always intended to convert onsite wastewater treatment into conventional sewer. Do it. There is nothing in the sewer ordinances that suggests that sewer has to be centralized and can not be distributed.
    Most of what we need to do it is already available. It simply needs to be reassembled into institutional and programmatic structures that release instead of inhibit its potential.

    I offer as references:

    G. Tracy Mehan; Assistance EPA Director for the Office of Water (2001-2003)
    Jeffrey Osuch; Executive Secretary for the Town of Fairhaven.
    Dr. Jean MacCormack; Chancellor, University of Massachusetts Dartmouth
    Dr. John Farrington: Dean; School for Marine science and Technology University of Massachusetts Dartmouth
    Thank you,

  13. March 19, 2010

    1. We have seen many farmers working to keep soil and nutrients in place on their farms and fence cattle out of streams. Voluntary efforts are paying off. Strong-arm tactics backfire.
    2. It is well-known that about 95% of phosphorus (P) in rivers is on soil particles, so keeping soil in place must be a very high priority. Most of the problem of (P) in estuaries and rivers is due to dams being demolished and legacy sediment being washed downstream, and other dams loaded with silt so that any new silt added to rivers is forced to go over the remaining dams as well. We need to make sure that our computer models estimating damage to ecosystems are not flawed, and that costs of “cleanup” do not exceed benefits.
    3. (a) The Lancaster County PA Conservation District and the Lancaster County Farm Bureau have developed a “Fence ‘Em Out” plan that encourages fencing livestock out of streams similar to the “flexible fencing” program of the Shenandoah Valley, VA which can be replicated widely.
    (b) No-till and limited-till plans are growing in popularity nationwide and can be encouraged further.
    (c) Educational materials on holding nutrients in place on soil can be disseminated widely

  14. March 19, 2010

    The root cause of our environmental problems, including negative impacts on watersheds, is worldwide human overpopulation and continuing population growth, which results in overconsumption of our natural resources and pollution of our global aquatic environment. Treating the symptoms (water pollution, excessive stream and river diversions, deforestation, climate change, lower water tables, etc.) of population growth will not solve our watershed problems in the long run, unless worldwide human population numbers are stabilized, or preferably reduced, in the future.

    I hope that the EPA and other government agencies (Federal, State, and local) and politicians will garner the political will to address the population growth issue by supporting voluntary family planning education programs ASAP. Not only is family planning cost effective, but it should be one of society’s top priorities as well.

    As a retired senior fisheries biologist, I can say that nearly all of my colleagues agree with me that human population growth is continuing to decimate our native fisheries and their habitats by making unsustainable demands on the aquatic environment. This trend must be halted before it is too late to turn things around.

  15. March 19, 2010

    I do not feel any success will be made in maintaining and improving the water quality and water quantity of our watersheds and individual streams until several existing elements are brought together and integrated into one sound paradigm, law,or enforceable rule. First regional approach to watershed management concerning any planning and implementation of proposed development including cumulative existing impacts and new potential impacts to be combined and calculated as planning tool. This would include individual watershed models that would have each additional applicants impacts added in. At such a time when the cumulative effect of the watersheds individual existing impacts are quantified and added up and include existing nutrients levels, erosion existing damage and levels , farm acreage, development acreage, total impervious surface, malfunctioning and total number of storm water devices, benthic macroinvertibrate diversity and health, and riparian soil health and amounts, and abilities to maintain and address base flow. If all these elements are not on a regional check list for each watershed with limits set for a combined and individual report card the point of TMDL,s is not as effective. Second a formula should be created that addresses all the above individual stream impact elements and creates a score card that can given planners,planning boards, zoning boards, counties,and states, a tool to know if a stream itself has reached build out. After such a score is given and limits are known a stream may or may not have already become impaired if impaired and score card shows excedence of any impacts TMDL,s would have to be created and enforced.
    Our stream Crafts Creek continues to be under an assault from a huge potential for increased erosion and flooding from excess of storm basins that all add extra flash flows by increasing pre construction run off due to non adaptive design criteria .With dozens more basins in the application phase and Crafts Creek already flooding in 100 year flood plain from normal rain events destruction is close at hand. Our stream is in danger of becoming nothing more than a huge erosion ditch adding to the degradation of Delaware River.

  16. March 19, 2010

    Establish a dam removal / sediment cleanup fund

    Dam removal can result in dramatic and rapid improvement to river health. Across the country, momentum is building as local communities, NGOs, state and federal agencies realize and act on the benefits of removing structures from our waterways that are failing and/or no longer serve any useful purpose.

    Unfortunately, the cost of contaminated-sediment cleanup prevents many dam removal projects from moving forward. In those situations, what remains is literally a ticking time bomb for our watersheds. Eventually, many of these dams will fail, and uncontrolled releases of contaminated sediment will occur. There are few alternative outcomes when the dam owner does not posses the financial resources to maintain the structure, let alone pay for costly sediment remediation.

    Strong consideration should be given to the establishment of a dedicated federal funding source for contaminated sediment remediation. At countless sites, thousands of cubic yards of sediment containing PCBs, heavy metals, insecticides, and petroleum by-products are ripe for removal. Dams have been remarkably effective sediment traps over the past centuries, and now store an enormous volume of contaminated material. Let’s seize on this opportunity to forever rid our waterways of this material, and turn this ‘problem’ into an ‘opportunity.’ A major federal commitment to financing sediment cleanup is critical to the dam removal movement currently in progress, and for the future health of our watersheds.

  17. Charles Deering permalink
    March 19, 2010

    More signage would help raise awareness that streams, wetlands and watersheds are loved and valued by someone.

    Every road crossing should have signs identifying the body of water being crossed. This should also apply to wetlands and even watersheds and aquifers. I do cleanup at favorite toss sites in the Potomac Watershed. Folks who pollute often view these sites as unloved wastelands. If they knew the body had a name and that some people love it, they might think twice.

    In cases where a body of water has no name, a community or school campaign to come up with a name would raise awareness about the site.

    A variety of agencies would be involved, like highway departments, planning boards, and parks departments

  18. March 19, 2010

    I am a watershed coordinator for MRRP, which is a NPO watershed group in Dickenson County, Virginia. The successes in this area with cleaning up our watershed has been wetlands and planting trees. Since this is a heavily mined area, planting trees is extremely beneficial because it makes the soil stronger and more absorbent. Planting trees, brushes, and other native plants along riverbeds are important as well because they act as riparian buffers. Wetlands are the biggest importance for ANY watershed. Wetlands filter run-off the best, balance pH, control flooding, and promote biodiversity. We have yet to construct a wetland yet, but if you need to Tom Biebighauser is the best and cheapest route. Mr. Biebighauser works out of Morehead State University, and has planned and help construct over 50 wetlands around the country and Canada.

    However, since the reforestation projects we have seen a decline in E. Coli content, pH balance, decrease in turbidity and sediment in most of our streams.

  19. March 19, 2010

    1) As with anything, there has to be a push and there are cost involved. 2) I would contend there is a good bit of information/research in this area. 3) It is always a question of balancing the public with the private sector. It seems the private/development sector has the advantage.

    In rural areas the watershed approach would seem to be practical. Given that in many cases land is available, often times it is just a matter of moving from point A to point B to alleviate a problem. Case in point, a farmer feeds his cows by the creek. Just by moving the cows 200 yards up the hill, would go a long way towards removing impacts to the creek. However in cities the problem is much more complicated. Access to buffers is almost non existent. Storm water discharges are in most cases directly to the stream. This is a problem with pollutants as well as the volume and velocity of the discharge. This doesn’t include the problems with old infrastructure. New development can be mitigated through new regs and rules, however in areas of old development, the cost can be quite prohibitive in trying to retrofit systems.

  20. March 19, 2010

    One of the best ways the EPA could help protect and improve the watersheads is to support organizations like the California Ocean Protection Council in their endeavors regarding Ocean Monitoring. Additionally,support the Marine Protected Act and the Marine Life Protection Acts to establish State Marine Reserves(SMR). These areas, like wetlands, could be used to study their ability to sequester greenhouse gases and as pollution reducing projects are implemented and the health of the SMR’s are measurably increased, possibly be revenue generating in the carbon trade market.

  21. March 18, 2010

    Aldo Leopold first proposed “skyline zoning” in the 1930s, knowing that if there were problems at the tops of watersheds, they would impact any restoration work further “down” the watershed. There are a number of wetland plants that can take substantially degraded water quality, e.g. river bulrush. NO amount of regulation or government demands can substitute for an educated populace voting with their pocketbooks. When we start going “green” — really “green,” not chemlawn green, with our commercial and residential landscapes, then we will make real progress with improvement of water quality. As far as EPA, I agree with above statements that (1) cooperation and coordination is necessary between whatever govt units and private NGOs and landowners are in the watershed; and (2) EPA grants to private landowners should be much easier to apply for and receive. I know a number of private landowners who have been trying for years to get assistance with projects which would substantively improve surface WQ, filtration, etc. and we (landowner and me) can’t even get calls back from govt agencies.

  22. March 18, 2010

    When Congress passed the Clean water Act, it demanded a ‘technology-based’ implementation program’ by demanding best available sewage treatment and specifically rejected a ‘water quality- based’ program, which could be too easily manipulated by local politicians and thus defeat the intent of the Act itself to set uniform national sewage treatment standards.

    Since watershed programs basically are water quality- based programs they may make sense, but should not be used to set treatment standards for point source sewage treatment. Those treatment standards should have been established by EPA, which it however could not do, because of the incorrect use of the BOD test, making it impossible to evaluate treatment efficiencies and comparing the different sewage treatment processes available, hence establishing ‘best available treatment’ criteria.

    Correcting the BOD test and regulations are essential to implement the CWA as it was intended and also would solve many of the problems now encountered in the field and hindering solutions to clean up our open waters.

  23. March 18, 2010

    Drugs are chemicals too, and the most dangerous chemicals we make right now are pharmaceuticals. I don’t care how much aspirin or shampoo is in the water. For the most part pharmaceuticals at very low levels are not dangerous. However there is a category of drugs defined by OSHA (occupational safety and health administration) as hazardous drugs. OSHA has a list of 61 of them and NIOSH (national Institute of occupational safety and health) has a list of 140 four total of around 200 chemicals that are so dangerous that there is zero exposure allowed to people handling these chemicals. The chemicals are made by men in spacesuits and prepared by pharmacists in a level III biological safety cabinet as if they were anthrax. The chemical is then injected into the patient and in most cases he is sent home. Most of these drugs are cytotoxic and used to treat cancer patients.
    As with every drug there is an absorption rate, the analogy I like to use is if you ever take a vitamin a couple of hours later you go to the bathroom your urine is a strange color it almost looks like you ate your highlighter. The color is the unaltered Vitamin passing through your body. Same thing happens with the chemotherapy drug, the absorption rate is typically very low sometimes less than 1% and that 1% that gets absorbed by the cells makes the patients hair fall out. The rest of it goes down the toilet into the septic system and if you’re a septic system you probably on a well and the drug is going directly into your drinking water.
    The mechanism of action of cytotoxic drugs is to break into the cell attacking DNA and break off the chromosomes thereby mutating the cell. So when the cancer cell splits it has been mutated it is no longer a cancer cell, as happens with all cells affected. The drugs tend to work on fast-growing cells like hair, skin cells and the fastest growing cells we have, embryonic, people being born. Chemotherapy drugs are administered at all different levels some of them are injected into the patient at a nano gram per liter that is a part per trillion. Another analogy I like to use is if you have a trillion one dollar bills the stack them like a deck of cards it would reach from Boston to the middle of Ohio. And one dollar out of that trillion injected into a patient where only 1% is absorbed by the body and nearly kills the patient. Where does the rest go? You guessed it right down the toilet and into the drinking water.
    A material safety data sheet for a cytotoxic drug states that it causes cancer, that it causes hereditable genetic damage and harm to the unborn child. Scientists believe that autism is a genetic disorder that is not hereditary, how do you have a genetic disorder that is not hereditary? You mutate the genes. One class of chemistry is designed specifically to mutate human genes and that is cytotoxic drugs.
    I’m not saying to discontinue the use of cancer curing medicine I only suggesting that we contain the excrement from patients on these drugs. Every drug that is approved by the FDA must state the absorption rate in the body as well as how quickly it is excreted. Most are excreted within 72 hours. We just need to contain the excretion before it gets into the environment and properly dispose of the waste.
    We should care about a chemical that is designed specifically to mutate human genes, is made by men in spacesuits, prepared by a pharmacists in a level III biological safety cabinet and is effective in a nano gram per liter.
    I have a lot of information generated by OSHA the EPA and the American chemical society to back up what I am talking about, and even more information on how to safely collect and dispose of the waste generated by our quest to cure cancer.

  24. March 18, 2010

    I have been involved with teaching students how to perform watershed assessments while working with the local communities. While hard, there is no better way to develop an assessment and stewardship plan that the community will accept as their own. Please continue to focus at this scale and encourage student training efforts to help local communities.

  25. March 18, 2010

    Water pollution loads from atmospheric deposition that originate in areas outside the local juridiction is an issue of national importance, especially for nitrates and mercury. This is not an issue that local legislation can impact, but the impacts to local communities is substancial. There must be national policy and inforcement on air emmissions that cross political boundaries.

  26. March 18, 2010

    1. Increasing participation by watershed residents is critically important. Four northeast Iowa watersheds have achieved participation levels of 40 (first year), 45, 65 and 70 percent. Participation rates like these build a watershed community and sense of obligation that the problem should be addressed by everyone, not just a few. The size and shape of the watershed is important – residents must be able to relate to others in their watershed outside of the watershed community, such as a common school, town or church. Our lowest participation watersheds are across more than one school boundary or are long and narrow where the people at one end do not know the people at the other end.

    2. Providing specific field, farm and watershed performance data to residents and farm operators is quite important. Performance measures in the field must be relatable to water quality such as a phosphorus index or an agronomic nitrogen management performance that can be related to P and N results in the stream. Individuals must be able to compare their performance data to others in the watershed for it to make any sense or have an impact to promote change/improvement. Our results show that no one wants to have the worst performing field or farm a watershed.

    3. Developing effective watershed councils, not just advisory boards, can be quickly scaled up on a state and national level if policy allows these councils to manage targeted watershed funding to improve their watersheds. Funds will be used more effectively on practices that are acceptable in each specific watershed and by allowing the councils more autonomy they can provide more flexible and inclusive incentive programs that increase voluntary participation. Determining baseline performance levels for watershed fields and farms will be a somewhat time consuming process, but once baseline levels are known watershed councils can set specific performance goals and watershed farm operators can adjust management strategies to work toward reaching these reasonable performance targets.

  27. March 18, 2010

    I believe the watershed management approach is a good way to incorporate multiple stakeholders in building ownership and leveraging the resources needed to solve a complicated problem. In states where this has not been supported or required on a widespread basis, as it has in Oregon and California for example, there is still a long way to go in building local capacity for holistic watershed management. In my 12 years of coordinating collaborative watershed management in NC, I am seeing that success is dependent upon a combination of the following factors:

    – A university or non-profit (such as a watershed group, or council of local governments) has staff with expertise in watershed science and public engagement, and funding dedicated for their time to lead watershed planning & implementation. Local government staff and citizen volunteers typically support and participate in efforts but do not lead them. Our state agencies will fund efforts, conduct scientific analyses, participate as technical help, occasionaly lead planning efforts required to meet specific wetland/stream mitigation needs, and conduct wetland/stream restoration projects to meet mitigation requirements.

    -Funding is accessible from state and/or the federal government to implement restoration, protection, and educational projects. I’ve seen a limited number of local governments partially fund efforts, though they are more likely to provide in-kind cost-sharing through time, equipment, and meeting space. Funding from some private foundations is possible but doesn’t appear to be widespread for this type of work.

    -A minimum small core of local government staff, elected officials, and citizens are supportive, provided information on issues, and willing to get engaged.

    -A federal or state regulation drives local government planning to meet those rules (such as Phase II Stormwater Rules or rules specific to impaired waters such as the Neuse or large drinking water supply watersheds)

    – A perceived or actual crisis with natural resources drives a community to participate in a planning process

    Our state’s current model of relying on grants (mostly EPA319) to conduct and implement watershed planning results in scattershot efforts to restore impaired waters across this particular state, with occasional focus on protecting healthy waters. Some larger municipalities here do choose to enact and use stormwater utilities to fund watershed management efforts (Durham and Wilmington, NC are examples). Some (an example is Raleigh neighbor, the Town of Cary, at 130k people and rapidly growing) rely on the regular budgeting process to fund stormwater management activities, so in a bad economy, forget about it! If federal and state resources continue to be as limited as in the past, we will continue at this slow pace of watershed restoration and protection.

    Focusing on protecting existing healthy watersheds is a good idea, particularly if incentives can be provided for local governments to adopt LID friendly ordinances, or to require LID. But also continue supporting work on restoring impaired watersheds- these often occur in high density areas where people see, interact with and care deeply about their natural resources. It is worth the resources to try to restore them- we should not give up.

    Regarding the question of how to “scale up” with watershed management, I think that needs to be driven by and coordinated by state agencies. I believe most people are happy to spend a little time getting to know their upstream and downstream neighbors if provided the opportunity, but will work hardest in their own communities. Yearly planning or engagement exercises is probably a good way to engage people on a larger scale.

    Thanks for the opportunity to provide input.

  28. March 18, 2010

    When you look at our agricultural landscape, there are several things that should be obvious. First, the majority of our land is tilled and bare 2/3 of the time in a corn-soybean rotation. Live plants absorb soluble N and P. If you look at our best managemnt practices: buffers, waterways, cover crops all involve live plants. We should be using practices that mimic natural cycles. No-till plus a cover crop mimics natural cycles. Cover crops are making no-till work better. Look at topics discussed at the National No-till conferences.

    Second, if you want to store more N and P in the soil, increase the soil organic matter (SOM) through carbon sequestration. Every 1% SOM in a six inch layer (15cm) holds about 1000 pounds of N. Considering that we have lost 60-70% of our SOM in the last 100-150 years due to excessive tillage, the soil can not hold as much N or P. Increase SOM (no-till plus covercrops) by 4-5% and you can hold 4,000 to 5,000 pounds more N and possibly about 100 pounds of P for every 1% SOM or 400-500 pounds P

    Third, increasing SOM and live plants has another effect. Soil bulk density decreases which means that water infiltration improves and their is less water runoff, less erosion, and less sediment losses (high in N and P). Live plants slow down runoff, decrease flooding, AND absorb soluble nutrients. More N and P are recyclcled in the soil profile.

    The other benefits include wildlife habitat, less carbon in the atmosphere, less fuel used for tillage, and possibly an energy source for ethanol. Support research and policies that use no-till farming with cover crops at the State and National level!

  29. March 18, 2010

    When will the EPA address the issue of Pharmaceuticals and Personal Care Products (PPCDs) in wastewater? The FDA issued a position paper four years ago on the subject but there is no regulations in place for our local agencies to follow and many are unaware of the biological impacts on humans and aquatic life.

  30. March 18, 2010

    Achievable baseline regulation and policies for major watersheds is a must. We have found that from county to county policy varies too much and is not sensitive to watershed boudaries. It also creates a climate of distrust among counties, cities and regions. We are involved with a program developed in Minnesota that is called Community Clean Ups for Water Quality that really engages communities that should be spread nation wide. It sensitizes residents to the impacts of urban storm water and directs them to how they can individually or collectively prevent phosphorus and nitrate pollution from entering our surface water. The program is being rolled out state-wide and has been recognized for a Governor’s Award this year. Also we have agricultural tile drainage across the Minnesota River Basin that impacts our surface water significantly. We are engaged in introducing technical advances that exist right now which can increase crop production, reduce phosphorus, nitrogen, reduce rate flow of drainage water and recharge ground water that used to escape the system. This is also that is something that should be spread throughout the corn belt and any other area that uses plastic tile drainage. The term is Conservation Drainage. I would be glad to talk to anyone who will listen about these replicable actions which have proven measurable positive outcomes

  31. Lori permalink
    March 18, 2010

    I agree with Peter Schultz on native vegetation, it will help clean up the waterways by being natural filters. Having said that, I work on a highly polluted river doing water quality monitoring that I belive won’t be cleaned by vegetation even if we take out all of the lawns around it and plant only native vegetation. Everyone in the city knows the river is polluted; it smells, it has an oily film over it sometimes, and has a lot of foam at different areas. Studies are being done to reduce pollution on this river, but as Margherita says, funding and administrative barriers prevent its clean-up. We know what’s in the water, we know why it’s there, we know how to fix it, but the fix is a very expensive project. The City doesn’t want to tackle it because that means they won’t get to build their next multi-million dollar complex for limited use but beautification purposes.
    I’m sure this happens in a lot of places; they know why and they know how to fix it, but no one is determined or foresighted enough to plan for a large and costly fix that will benefit more than just the people of the city. The problem isn’t in the fix itself (i.e. what to do), the problem is in the planning and implementation of the fix.
    P.S. Tighter laws and regulations on dumping into an area that will affect a watershed (e.g. pesticides and herbicides from farm run-off) and elimination of combined sewer overflows.

  32. March 18, 2010

    I agree that watershed management is key to keeping our waterways healthy. Here in Florida, and I’m sure this is common, we have lake management companies hired to keep lakes beautiful and we have landscaping companies hired to make communities beautiful. Unfortunately, these two entities almost never coordinate. I work for a lake management company, and many of our challenges in the water stem from lawn fertilizers and grass clippings beyond the shoreline. If regulations don’t start in the watershed, we cannot meet mandated goals for the water.

  33. March 18, 2010

    Almost all of us in the environmental world recognize the need to address problems on a holistic, comprehensive scale, whether that scale is watershed or airshed, or some other credibe “shed.” But at the tedious administrative level, one of the most frustrating barriers we face is the maze of conflicting and/or disconnected programs and funding sources that positively discourage such an approach.

    Most of our federal agencies love to hand out money to to move dirt around; for us, that’s considered implementation and we can pat ourselves on the back for getting a project done. But even small restoration projects — especially in urban areas — can be extremely expensive and time-consuming. They need upfront planning, commitment to the long haul, and continuing project oversight. Yet there is very little if any support for the non-construction work of identifying the problem and effective solution, preparing the technical specifications, negotiating the array of permits and public outreach processes, contracting with construction or other entities, and in general holding the effort together. And all of this doesn’t even take into account the differing match requirements for federal funding sources, few of which can be combined with each other and all of which have their own application, reporting, and disbursement rules. Particularly for small grass-roots organizations, the passion and local knowledge they bring to their projects can quickly be withered by the competing demands of their various funders.

    I recognize that we operate under different legislative authorities and misssions. Some requirements are based in statute. But if we are serious about seeking local, public engagement we have to make it easier and more efficient for organizations to work with us. Surely a topic for the summit could be consideration of ways agencies can pool their funding or develop common project application and matching processes.

    These aren’t soaring or visionary suggestions, but they might make it a little less daunting for our partners to actually begin operating under a watershed approach.

  34. March 18, 2010

    The watershed approach EPA and other partners has promoted over the years is sound and should continue. However, I believe we have all been unrealistic is establishing timelines for watershed recovery, especially on large systems like the Potomac River and the Chesapeake Bay. These systems have been impacted for approximately 400 years and it will take some time for them to recover.

    That said, setting tight deadlines for speeding restoration is a necessity. The TMDL program falls short in that there are no specific deadlines associated for implementation when plans are developed. The Chesapeake Bay TMDL is the only one I am aware of where there are specific timelines and consequences being established for not meeting specific restoration goals.

    EPA needs to increase enforcement programs as well as ramp up voluntary programs so that citizens can easily become engaged in restoration efforts. One of your biggest hurdles to overcome is that many do not believe they can make a difference. To that extent, EPA needs to ramp up Environmental Education to both K-12 as well as communities, especially in urban communities.

    It is time EPA started focusing on smal watersheds with targeted efforts so that you can start to see measurable success. You can engage citizens through volunteer water monitoring programs as a way to engage and educate them. High quality data collected by these citizens can be used to directly measure the success of conservation efforts in the watershed. This effort not only educates, but provides valuable data. You should look to Virginia’s use of Volunteer data in their 305(b)/303(d) programs to understand how citizen data can be effectively utilized throughout the nation.

    Last, EPA needs to bring funding to the table in order to implement watershed plans. People are tired of money being spent developing these plans only to see them sit on a bookshelf gathering dust. The methods being developed to achieve “reasonable assurance” with the Chesapeake Bay TMDL needs to be applied nationwide. This needs to occur on all scales of TMDLs – small watershed and as wel as large systems.

  35. March 18, 2010

    Corn bio fuel, a forth grader knows corn needs much fertilizer++
    Agriculture back sets from the water are 25 ft ++ run off of fertilizer and irrrigation/stormwater.
    Chicken farms need to run the waste into the bay or the price of a chicken would be too high??
    Square miles of tailings from Sparrow Point heavy metal runoff ??
    Pressure filling with ?? fluids for natural gas collection ?? at what cost to our waters and dependant creatures?

    Our tiny river (a 1 mile back bay) is in the direct flow of the Susquehanna River south along the western shore of the Chesapeake Bay (dead zone). The Susquehana River Watershed has the highest concentration of population of people and animals on the east coast.
    Rt 50’s runoff west of the Bay Bridge flows into our river. Cat Branch is a 1 1/2 mile fresh water stream flowing into our river along with every development’s storm water they could direct to it. This includes 5 cluster communities built scince the 80’s with their stormwater outlets right into the stream bed, a large High School, 3 recreational parks, and a large church.
    This jewel on the flyway is spring/summer home to Eagles, Ospeys, Perigrine Falcon, Great Blue Herons, King Fishers, Egrets, River Otters, Cormorants and Muskrats. In winter we see hundreds of Canada Geese, Canvas Backs, Hooded Mergansers, Trumpeter Swans, Mallards, other diving ducks, Deer, Rabbits and Snow Geese.
    The question, will the river fill in before it is unusable by any species?
    We are trying to save our stream, a sub watershed of the Magothy River in the EPA watershed of the Lower Western Shore of the Chesapeake Bay. We can’t change what is coming at us in every direction. There is no industry maritime or other use. The property owners on the river do manage their runoff, except of course the cluster communities. Pet owners are doing their part. There is a rain garden to capture the sediment from the ball field in our community. There is little use of fertilizers. The main community on the river was developed in the 50-70’s by individual builders. There are 100 yr old trees, and it is well forested.
    It is our governments that let us down, with mismanagement of stormwater, and poor enforcement of existing laws and regulations.

  36. March 17, 2010

    1. Close loopholes for non-point pollution where they are due to regulatory decisions rather than weaknesses in the Clean Water ACt.
    2. Do not allow states to weaken “intended use” designations, as I think is being considered presently in Texas.
    3. Raise awareness of the role of native vegetation, especially deep-rooted perennial grasses, on the amount, time-course, and water quality of runoff in the plains states. Then, find ways to encourage landowners to re-establish native vegetation for the purpose of (among other things) protecting the downstream watershed.

  37. March 17, 2010

    A watershed approach provides a more comprehensive method of balancing economic, social and environmental issues.

    An excellent example of an industry, state government and university partnership is the Clean Marina Program.

    Despite the lack of significant, sustained funding, many states have developed Clean Marina programs that are based on voluntary participation. These programs focus on best management practices that go above and beyond state and federal regulations to protect water quality.

    Michigan Sea Grant recently invested $100,000 in the development of an online Clean Marina training program that may eventually be applicable for any freshwater marina in the U.S. Clean Marina efforts have involved consulting with and training hundreds of marina owners and operators.

    Marinas provide access to our coastal areas and are an essential component of coastal economies. Certified Clean Marinas are wonderful examples of watershed stewards.

  38. March 17, 2010

    The Watershed Approach is excellent. I am currently working on the North Branch Park River Watershed Management Plan project team, see

    Here are my (quick) observations:

    1) There needs to be stable funding for a public outreach/message coordinator, in order to engage the community in the watershed management plan. As state budgets are cut (unfortunately), there needs to be support for the evolution of citizen stewardship.

    2) Schools (K-12 and higher ed) can bring community energy to the process of learning about local water quality issues – yet there needs to be clear educational guidelines and support for teacher/community stewardship training activities.

    3) The professional design community needs to recognize that watershed management plans are a key resource for site specific planning. A lot of design firms (planners, engineers, architects and landscape architects) seem willing to overlook watershed management and water quality interests – as if these watershed management plans were just another formalist concept.

    Trained as an architect, I would frankly rather be involved in the design of green infrastructure – however the message and potential of watershed planning has not been fully integrated into planning and design practices. Thus I am working as an advocate to establish the stewardship values that will be needed by the next generation. Hopefully Obama EPA will assist the grassroots by becoming leadership change agents.

  39. Beverley permalink
    March 17, 2010

    A watershed approach to protecting water resources can only work if it is taken seriously enough that watersheds not broken up by political boundaries. Currently the Sacramento River watershed is broken up by numerous counties and the mainstem of the river itself below Keswick Dam flows through and past 7 counties before even reaching Sacramento. That is 7 counties with different regulations and different levels of concern for the water except, in the extreme, to take what they want.
    Additionally, watershed groups and watershed protection are largely funded by bond funded grants, at least in California which may or may not be available and, as we saw, in 2009, subject to freezing and the whims of the State government in it deems important enough to get funding restarted to.

  40. Mandy Barre permalink
    March 17, 2010

    More funding must be made available for upstream projects and coastal projects. Coastal cities rely on tourism so testing funding is a must!

  41. Mandy Barre permalink
    March 17, 2010

    It’s important to clean the watersheds upstream..we all forget that water runs downhill! This seems like a stupid comment but it’s given in a most serious way. Stormwater must be contained certainly in the urban areas, agricultural runoff must be contained and minimized, and I agree that yard chemicals for the average homeowner should be banned.

  42. March 17, 2010

    This healthy watershed approach is critical to complement all the restoration work throughout the country.Our TMDL lists are growing but we do not have official lists of healthy watersheds ( non or anti-TMDL ) that should be available to public and growing in size like the TMDL lists are.This non-TMDL list of Healthy Watersheds should have implementation plans ,like the TMDL list does, to keep it on the non -TMDL list.

  43. March 17, 2010

    When I first started working on water issues a year ago I was astounded to find out that only 20% of the waters in Missouri are protected for fishing and swimming. I think people have the impression that someone is out there taking samples of all the waters, all the time to make sure that the waters are safe and clean when in fact there isn’t and they aren’t. Instead there is a permit process that does not look closely enough at cumulative watershed impacts and tends to bend towards the benefit of polluters to the detriment of the community’s water resources.

    I believe that the best way to motivate people to make informed decisions is to make sure that every watershed is thoroughly and periodically assessed and that these assessments are effectively and repeatedly communicated with the people and businesses that live and operate within each watershed. It is important to have communities engaged in the decision making process on a watershed by watershed basis.

  44. March 17, 2010

    Watersheds do not follow political boundaries. Therefore, a watershed-approach can’t be taken solely by one entity, agency, or municipality because the watershed exceeds its jurisdiction. You can manage your piece as holistically as possible, but if someone is managing or mismanaging their land upstream, it is all for naught. It takes collaboration of all entities working in some manner in the watershed. Collaboration is challenging and time consuming. A watershed approach needs an institution to match the scale; therefore, we need a legitimate watershed management department or unit, consisting of representatives of all entities working in the watershed, to undertake a watershed-based approach.

    For example, LA County established a Watershed Management Division in 2000 to address the flood risk management, water quality, water conservation, open space, and recreational needs. Rather than focus on single-objective solutions for these Flood Control District priorities, the Division uses an integrated, multipurpose approach that is consistent with watershed management principles. These principles are carried out through a framework of collaboration and partnerships, combined with sound science and local knowledge, as a foundation for well-planned actions. Outcomes are monitored so that multi-purpose projects may be adapted over time to achieve improved results.

    We will never truly achieve watershed management without encouraging partnerships such as this. One entity or organization cannot do it alone.

  45. March 17, 2010

    I have assisted with several watershed management efforts and when done properly the watershed approach is the most effective. In each case the key element is to get people to accept ownership of the issue and to build their capacity for making good science based decisions. Other things are needed – education, possible incentives, but the success is generally related to local people being asked what they are willing to do to help protect the environment and then getting them to act upon it. Getting a group in a watershed to work together requires time and patiences but the reward in long-term sustainability in watershed protection.

  46. March 17, 2010

    Combined efforts for protection and conservation of healthy, functioning watersheds need to give careful consideration to issue of dam removals. The debate over dams is stirring here in Ann Arbor and throughout the greater United States.

    River ecologists from all over the world agree: dam removal creates cleaner water, better fish and wildlife habitat, greater species diversity, improved flows and phosphorus reduction among other major ecological benefits.

    Federal agencies (including the EPA) who generally have jurisdictional control our nation’s dams and related structures have the opportunity to take an active leadership role so that we as a nation can scale dam removal efforts nationally.

    Perhaps most the most compelling benefit, especially in these tough economic times, is the substantial tax cost savings. Dam removals will save millions of dollars in costs related to maintaining these often outdated and failing structures. Associated maintenance and environmental costs will only go up over time.

    We need to adopt a national, micro-economic, watershed specific, strategy where we can target available Federal stimulus funds. Dam removal projects create jobs and reduce long term financial liabilities.

    We need leadership that does not accept the status quo on this important watershed issue.

  47. March 17, 2010

    As a followup to my previous comment on manure. In many states the major source of water pollution is storm water runoff. It’s a huge pollutant. When EPA required municipalities to run all the runoff through their waste water treatment plants they failed to provide funding for the increase in in volume leaving many without sufficient capacity to treat both human waste and storm water runoff. In many states, including the one I live in it is quite common for a municipal waste treatment plant to bypass or overflow untreated human waste directly into a water body be it large lake or small streams. The law allows them to do this to prevent backups in the system which would flood raw sewage into residents basements. They can also do it if they have a breakdown in a piece of machinery. During the spring of 2008 a state in the mid west was inundated with spring storms increasing the volume of waste coming into treatment plants. Regulators stated that at least 200 municipal waste treatment plants opened the valves and let all the untreated waste run straight through the facility for over two weeks. Billions of gallons of highly toxic human waste ended up in the states water bodies and the public blamed farmers even though the regulators reported it was municipalities.
    If you look at the components of cow manure and the components of human manure you will be shocked. Our waste contains all the medications we take only 10% of the pill is absorbed. Viagra, antibiotics and all other medication are found in large quantities in samples from the outfalls of treatment plants. The plants are not designed to filterer them out. Read the warnings on toilet bowl cleaner it is dangerous stuff. Every thing that goes down the drain or the toilet that cannot be filtered out is going into our waters. This can be halted in short order. Don’t allow any municipality that has had more than two sewage bypasses in any one year to put a moratorium on issuing any new building permits for structures that will connect to the sewage mains. Provide some cost share and issue statements that make the public aware of how large a problem this is. If they don’t know that they are significant contributors to significant water pollution, they will object to any tax increase to pay for improvements.

    Also, we have to stop putting sewage sludge which contains a horrific number of serous pollutants. Heavy metals, very dangeous pathogens, pharmaceuticals, chemicals from personal hygiene products cosmetics and the list goes on. Sewer Sludge or Bio-Solids are materials that cannot get through the filtering process and settle to the bottom of the tanks. It has not been treated in any fashion and it is being applied to land on which our food is grown. This is the most serious pollutant being put into our environment by millions of pounds a day and we hear nothing about it.

    Thanks for the opportunity to comment

  48. March 17, 2010

    Without land use planning and land use management, the watershed approach is missing the largest component to protecting water… MAN.

  49. March 17, 2010

    Viewing waterways as riparian corridors with parallel zones along either side will help to greatly improve water quality, habitat, and sustainable use, especially in areas where the rivers and creekways are narrow ribbons of water surrounded by essential migratory habitat.

    Perhaps the most educational effort I’ve participated in over the last 5 years was a review of a riparian corridor near Kerrville, Texas. One rancher allowed his cattle unrestricted access to a spring fed creek. Another adjacent rancher upstream allowed his cattle a narrow passage to access or cross the stream.

    The upstream rancher had a healthy cross-sectional profile to the habitat along almost all of his stream. There was excellent biodiversity. Trees, forbs, grasses and sedges were all balaced, healthy, and provided good cover. Downstream where cattle had unrestricted access to the stream in an area with virtually identical topography there was significantly less soil and ground cover and only about 10% of the species diversity. Both were successful ranchers but only the first protected downstream water quality, a natural flow regime, and a balanced habitat. The same riparian corridor approach can be used for ranching, the development of migratory pathways, or anthropogenic land uses. Limited waterway crossings that encourage natural habitat along the rest of the waterway will yield naturally healthier and sustainable uses.

  50. March 17, 2010

    1. I think that all lawn chemicals should be banned. I can’t even walk past them in a home store without feeling them in my nose and throat. I once read in a gardening book that lawns came about as a status symbol to show that a person was wealthy enough to afford not to have graze or plant all his land. There are many herbs and ground covers that can be planted that don’t need pesticides or extra watering, an added advantage. Also as Maria Rodale mentioned in yesterday’s Morning Call, dandelions are edible, good for you and free (as long as they are not sprayed. The public needs to be made aware of the history of lawns and the problems pesticides create for us all. We need the crying Indian back (or an updated version.)

    2. We need more vigorous policing of our lakes, rivers and streams for illegal discharges. This should be part of a WPA style recovery program. Unemployed people can be hired and trained to do this in their home towns. In this economy with universal health care still being held back from the people, we need ammunition to know who is making us sick. This could and should lead to a Health Care Superfund to provide the government with the means to protect people from not only illness, but bankruptcy when they get sick after 20 years of ingesting the chemicals that others make a profit from.

    3. The parks in Allentown PA are currently being restored and improved with money from The Trexler Trust. Included in these improvements are natural areas that protect both the water and the wildlife while also providing recreational activities for residents and visitors.

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