Jan Bowers Chester County Water Resources Authority

Transcription

1 Jan Bowers Chester County Water Resources Authority

2 *564 sq. mi. (397 in PA; 234 not in Urbanized Area) *3 states (PA/DE/MD) *4 counties (Lancaster, Chester, Delaware, New Castle) *Approximately 50% of Chester County *4 major watersheds (Brandywine, Red Clay, White Clay, Christina River) *1,240 miles streams (~30% impaired, 2014) *55 PA municipalities *(31 MS4s/TMDLs, 14 MS4s/no TMDL, 10 non-ms4s) *259,000 population

3 *Early 1990 s news photo Governor Carper in canoe facing north pollution from PA *Non-profit filed law suit against EPA for not enforcing CWA in Christina EPA lost; court mandated EPA to develop Christina TMDLs for DE & PA *1995 EPA asked DRBC to work with PA, DE *Christina Clean Water Partnership formed *Inter-state, inter-level goverments, non-profits * Check your guns at the door *Evolved to current strong working relationship

4 *Separate TMDLs for PA & DE *PA - Bacteria and Sediment (9/2006) *Sediment WLAs (28 municipalities with WLAs, 2 non- MS4s) *PA - Nutrient and Low Dissolved Oxygen (High Flow) (9/2006) *Nitrogen WLAs (26 municipalities with WLAs) *Phosphorus WLAs (26 municipalities with WLAs) *Focus only on 1996/1998 impairments *Many questions, ambiguities, inconsistencies, erroneous data, etc. in the TMDL reports

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8 *Chester County Portion of the Basin *32 municipalities *MS4s, non-ms4s, WLAs, non-wlas *Brandywine Red Clay Alliance lead coordinator (formerly Brandywine Valley Assoc.) *Chester County Water Resources Authority *Chester County Conservation District

9 *2003 MS4 program started *BVA partnership with MS4s for MCMs 1 & 2 *2007 DEP asked CCWRA/CCCD for assistance in addressing MS4 and TMDLs in Christina *2008 MS4 Permit Renewal (scheduled) to include TMDL requirements *CCWRA/CCCD offered to coordinate; Municipalities requested to expand relationship with BVA to include MS4/TMDL coordination *Letters of Agreement with BVA

10 *2007- began regular meetings (still meet regularly) *CCWRA/BVA - liaison between Partnership and DEP for technical interpretation/clarification *Many questions, ambiguities, inconsistencies, erroneous data, etc. etc.in the TMDL reports *Numerous meetings, letters, s, discussions with DEP staff (SERO, HQ, TMDL group, etc.) *Meeting with DEP and EPA * Best available information, use it

11 *All municipalities were committed to improving water quality in ALL CURRENT stream impairments of the watersheds (not just 1996/1998 impairments) *Commitment to collaboration and cohesive watershed-based approach

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13 *BMP/Project Collaboration is NOT an alternative for these TMDLs *Localized and disbursed stream impairments *Inconsistent and limited geographies of the 96/98 impairments, UAs, MS4 regulated areas, etc. PRECLUDE collaboration on projects *Can t get credit for BMPs installed outside of their regulated MS4 jurisdiction *Can t get credit for pollutant reduction that is not to the TMDL streams they are discharging to

14 *But technical collaboration and coordination ARE improving MS4 & TMDL implementation: *Coordinated information sharing, *Clearing-house of reliable technical material, *Online tools, maps, documents, GIS data and layers, *Joint meetings/discussions with DEP to improve understanding of TMDL and MS4 requirements, *Christina MapShed pollutant reduction model to track improvements & evaluate scenarios

15 *CCWRA prepared a thorough MS4 TMDL Strategy Template *user friendly, streamlined *pre-formulated spreadsheets for parsing *maps *spreadsheets of WLAs *included all components required by MS4 permit *group and individual training and coaching

16 *Provided consistent, coherent, scientificallybased approach, completely consistent with TMDLs and MS4 permit requirements *Streamlined and consistent to ease DEP review *Used by most MS4s for 2012 submittals *No problems noted by DEP with template *Some used incorrectly *Not sure if being used for re-submittals

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18 *Municipalities most comfortable working with a non-advocacy non-profit conservation organization experienced in watershed restoration *TMDLs = Snowflakes *MS4s = Snowflakes *(lots of them; all very similar but no 2 are alike; can create a beautiful landscape; can be incredibly difficult to navigate through)

19 *MS4s CAN T collaborate for TMDL BMP implementation because of the very localized, disbursed impairments *MS4s CAN collaborate on technical information, tools, materials, data, regulatory interpretation, etc.

20 *Christina TMDLs are NOT an effective method for restoring water quality under today s regulations & extent of impairments *PRPs (2018 MS4 permit) will provide a much better approach for truly improving streams & may provided some (limited) opportunities for collaboration *DEP Offsets Policy is badly needed to encourage/allow more collaboration