jan bowers chester county water resources authority · strategy template” * user friendly,...
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Jan Bowers
Chester County Water Resources Authority
*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
*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
*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
*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
*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
*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, emails, discussions with DEP staff (SERO, HQ, TMDL group, etc.)
*Meeting with DEP and EPA*“Best available information, use it…”
*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
*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
*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
*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
*Provided consistent, coherent, scientifically-based 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
*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)
*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.
*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