missouri uaa protocol update by ed galbraith, barr engineering, at regform's 2013 missouri...

Missouri UAA Protocol Update

Ed Galbraith Barr Engineering REGFORM Water Seminary September, 2013

UAA Factors 40 CFR 131.10(g)

• 1. Natural Pollutant Sources

• 2. Natural, Ephemeral, Intermittent or Low Flow Conditions

• 3. Non-Remedial, Human Caused Conditions

• 4. Hydrologic Modifications

• 5. Natural Physical Features

• 6. Substantial and Widespread Economic and Social Impact

The “Outcomes”

1. Warm Water Habitat

2. Exceptional Aquatic Habitat

3. Modified Aquatic Habitat

4. Impairment

5. Remove Use

What do we want? When do we want it?

Permittee stakeholders want an off-ramp that

• Is easy to use and predictable.

• Is possible to understand outcomes beforehand

• Is not unreasonably expensive

• Is not fraught with uncertainty and risk

Would like a protocol in hand before rule is effective.

What do we want? When do we want it?

Environmental stakeholders want an on-ramp that

• Is easy to use and predictable

• Requires minimal level of effort to add waters

• Can be used by the public

Early Comments

• No provisions for flow –based decisions (permanent flow, permanent pools)

• Criteria do not distinguish between bins

• Some of the guidance documents and protocols are not applicable to headwater streams.

• Process for going from “information gathering” to “decision making” is a bit of black box.

UAA Factors 40 CFR 131.10(g)

• 1. Natural Pollutant Sources

• 2. Natural, Ephemeral, Intermittent or Low Flow Conditions

• 3. Non-Remedial, Human Caused Conditions

• 4. Hydrologic Modifications

• 5. Natural Physical Features

• 6. Substantial and Widespread Economic and Social Impact

Pop Quiz

Pop Quiz

Who is best former director of the Water Protection Program?

Pop Quiz

Does flow (or lack of flow) enter into the decision process? If so, what protocol do we use to determine whether the stream has permanent flow and permanent pools?

Pop Quiz

If a segment above the 100K is surveyed and there is no permanent flow or permanent pools is that an end point?

Pop Quiz

If a segment within the 100K is surveyed and there is no permanent flow or permanent pools, is that an endpoint

Pop Quiz

How would respond to this statement: The on ramp for a stream or lake should be no more than a photograph.

Pop Quiz

Should the level of effort to add a stream or remove a stream be:

a. About the same

b. The bar to remove a water should be a lot higher

c. The bar to add a water should be a lot higher

d. None of the above

Pop Quiz

If the criteria for the different habitats (warm water, modified, exceptional) are all the same, what is the incentive for someone to go through the process?

Pop Quiz

In the absence of numeric criteria, how will the data in the UAA be evaluated?

Pop Quiz

Give us a look into the review committee? How will the data be evaluated once the application is complete?

Pop Quiz

What is the air speed velocity of a swallow carrying a coconut?