• Greater opportunities for trading and other market-based approaches;

  • Reduced cost of improving the quality of the nation’s waters;

  • More effective implementation of watershed plans, including total maximum daily loads (TMDLs); and

  • Other ancillary benefits beyond those that have been achieved under the Clean Water Act (e.g., integrating CWA and Safe Drinking Water Act [SDWA] programs).

Subsequent to the policy statement, EPA published two guidance documents that lay out a general process for a designated state that wishes to set up any type of permit or permits under CWA auspices on a watershed basis (EPA, 2003b, 2007a). It also outlined a number of case studies illustrating various kinds of permits that contain some watershed-based elements. Box 6-1 describes in greater detail the more recent report (EPA, 2007a) and its 11 “options” for watershed-based permitting. Unfortunately, the EPA guidance is lacking in its description of what constitutes watershed-based permitting, who would be covered under such a permit, and how it would replace the current program for municipalities and industries discharging stormwater under an individual or general NPDES permit. Few examples are given, some of which are not even watershed-based, with most of the examples involving grouping municipal wastewater treatment works under a single permit with no reference to stormwater. Most of the 11 options are removed from the fundamental concept of watershed-based permitting. Finally, the guidance fails to elaborate on the policy statement goal to make water quality standards watershed-based. The committee concluded that, although the EPA documents lay some groundwork for watershed-based permitting—especially the ideas of integrated municipal permits, water quality trading, and monitoring consortia—the sum total of EPA’s analysis does not define a framework for moving toward true watershed-based permitting. The guidance attends to few of the details associated with such a program and it has made no attempt to envision how such a system could be extended to the states and the municipal and industrial stormwater permittees. This chapter attempts to overcome these shortcomings by presenting a more comprehensive description of watershed-based permitting for stormwater dischargers.

The approach proposed in this chapter fits within the general framework outlined by EPA but goes much further. First, it is intended to replace the present structure, instead of being an adjunct to it, and to be uniformly applied nationwide. The proposal adopts the goal orientation of the policy statement and then extends it to root watershed management and permitting in comprehensive objectives representing the ability of waters to actually support designated beneficial uses. The proposal builds primarily around the integrated municipal permit concept in the policy statement and technical guidance. Like EPA’s outline, the committee emphasizes measuring the effectiveness of actions in bringing improvements, but goes on from there to recommend a set of monitoring activi-



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