Measuring the Effectiveness of Watershed-Based General Stormwater Permitting

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ABSTRACT
The U.S. EPA and most water resources professionals advocate holistic and adaptive watershed management approaches to the protection and restoration of aquatic ecosystems by encouraging pollution control strategies that are developed through collaborative partnerships within a hydrologic boundary. This paper evaluates the effectiveness of the holistic adaptive management approach through a case study where the principles of watershed-based management and permitting have been practiced for over twelve years. Measuring the success of a holistic approach to watershed management is demonstrated through the presentation of monitoring data collected for the Rouge River watershed.

INTRODUCTION
The U.S. EPA and most water resources professionals advocate holistic and adaptive watershed management approaches to the protection and restoration of aquatic ecosystems by encouraging pollution control strategies that are developed through collaborative partnerships within a hydrologic boundary. In December 2002, EPA issued a watershed-based National Pollutant Discharge Elimination System (NPDES) permitting policy statement “to demonstrate the Agency’s significant level of support for developing and issuing NPDES permits on a watershed basis (Mehan, 2002).” The policy statement encourages “a detailed, integrated and inclusive watershed planning process” that “provides a framework for addressing all stressors within a hydrologically defined drainage basin instead of viewing individual sources in isolation (Mehan, 2002).” EPA introduced several possible mechanisms for implementing general, individual, and integrated permits based on collective and/or common sources such as all publicly owned treatment works, all confined animal feeding operations or all stormwater dischargers from municipal separate storm sewer systems (Mehan, 2002). Although this approach is quite different from the point source-focused regulatory framework that worked in years past, EPA’s vision and plan for advancing this innovative approach that adapts to today’s most pressing issues is compelling. This paper evaluates the effectiveness of the holistic adaptive management approach through a case study where the principles of watershed-based management and permitting have been practiced for over twelve (12) years.

MICHIGAN’S WATERSHED-BASED GENERAL STORMWATER PERMIT
Michigan was one of the first states to embrace and in fact help develop the concept of watershed-based general stormwater permitting. In 1997, as part of the Rouge River National Wet Weather Demonstration Project (Rouge Project), stakeholders in southeastern Michigan worked with the Michigan Department of Environmental Quality (MDEQ) to develop a voluntary watershed-based general permit for stormwater discharges. The permit was originally voluntary because there was no legal requirement for the storm sewer operators in the Rouge Watershed to have a permit. Now a regulatory requirement, the MDEQ offers a watershed-based general permit as one of two options for compliance with the NPDES Phase I and II stormwater regulations (MDEQ, 2006). The other option is a traditional jurisdictional-based permit.

THE ALLIANCE OF ROUGE COMMUNITIES
Approximately 75% of the municipal storm water permit applications received statewide by MDEQ in March 2003 were for coverage under the watershed-based general permit (Drullinger, 2003). In the Rouge River watershed, thirty-nine (39) individual communities and 3 counties in were among those to embrace this holistic approach by selecting the watershed-based general stormwater permit. Additionally, in August 2003, the communities and counties in the Rouge River watershed formed the Rouge River Watershed Local Management Assembly (Assembly of Rouge Communities) to continue the restoration of the Rouge River Watershed into the future.

The Assembly of Rouge Communities was a voluntary organization of the local municipal governments (i.e., cities, townships, and villages) and the three counties (i.e., Wayne, Oakland and Washtenaw) located in part or totally within the watershed of the Rouge River located in southeast Michigan. It was formed following nearly two years of discussion between the communities and the three counties who recognized that an institutional arrangement was needed to replace that previously provided by the Rouge Project. Membership in the Assembly of Rouge Communities was defined under the terms of a Memorandum of Agreement and was limited to cities, townships, villages and counties in the watershed that have storm water management responsibilities under a state-issued discharge permit. In addition, membership required the payment of assessments based upon equal weight given to community's population and land area within the watershed. The three counties were initially allowed to join based upon in-kind services provided communities.

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