Water in the West - Session 1 - Molly Blumhoefer


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Challenges, Constraints and Opportunities Associated with the Development of a NPDES Watershed-Based Stormwater Permit in the Middle Rio Grande Area

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  • The conference aims to explore transformational solutions – technical, or policy level, or both together -- that will return large-scale, non-linear changes to the supply-demand equation. Potential presenters are asked to look beyond incremental approaches (unless they are combined in such a way as to provide transformational results) and to think big, and out of the box. Where does the discussion begin and where does it end?water quantity and quality are invariably connected, especially if we bring both energy production or energy consumption into the equation. In the southwest we have used water to produce energy, we have used energy to clean water and we may be needing a lot more energy and a lot more water as our water resources dwindle and become more degraded with rapid urbanization. However, we are not left with many options considering the Water Quality vs Water Quantity Paradox that exists for our region and especially for our state. We are already issuing paper water (overadjudicatoin) for ground water and on top of it we are doing this in a watershed has been deemed degraded by the EPA because SWQS have not been met. If the office of the state engineer continues to issue paper permits that do not have the water to back them up, then the water quantity vs water quality paradox will only intensify. So, when the EPA decides to mandate measures under a new watershed-based permit that do not coincide with the state-run operations at the OSE of issuing paper water. The players within the watershed may become sandwitched between governments with opposing objectives. On top of this, there are many other challenges. What do you do as an entity mandated to comply with a new permit? You listen to the great teachings of jWpowell and abide by the EPA by trying to manage water based around hydrologic boundaries, rather than political boundaries. How? In the most basic sense, you turn to your neighbor for help—even if this neighbor is your arch enemy. This is the only approach to making the appropriate connection across political barriers.
  • It is difficult to implement a watershed approach that operates on the production of positive externalities that are not being financially compensated for and where a method by which charging those stakeholders that create negative externalities within the system is not yet determined
  • Individuality outside of sector demarcation
  • -The closer you are in physical proximity to an entity under the same SWMP,-prevent redundancy in administrative tasks such as monitoring and ordinance developmentwould group entities together that are not as similar in administrative capacity and operational function within the watershed. -Therefore, they would have a larger spectrum of resources and authority from which to work and identifying pollutants
  • Water in the West - Session 1 - Molly Blumhoefer

    1. 1. Challenges, Constraints and Opportunities Associated with the Development of a NPDES Watershed-Based Stormwater Permit in the Middle Rio Grande Area By Molly Blumhoefer
    2. 2. Introduction •2006 – EPA commissioned National Research Council to review the national stormwater program •2008- the NRC report recommended the nation revise its stormwater management program to ensure that it meets the criteria set forth in the Clean Water Act (CWA) •2010- the EPA initiated three pilot projects to assess the practicability of issuing watershed-based Municipal Separate Stormwater Sewer System (MS4) permits for urbanized areas Ramsey Washington Watershed District, MN Middle Rio Grande Watershed District, NM Milwaukee Metro Watershed, WI
    3. 3. EPA Draft Permit (2013) NPDES Permit No. NMR04A000
    4. 4. Possible Permittees & Classifications under new Watershed-Based Permit Class A: City of Albuquerque AMAFCA (Albuquerque Metropolitan Arroyo Flood Control) UNM (University of New Mexico) NMDOT (New Mexico Department of Transportation District 3) Class B: Bernalillo County Sandoval County Village of Corrales City of Rio Rancho Los Ranchos de Albuquerque KAFB (Kirtland Air Force Base) Town of Bernalillo EXPO (State Fairgrounds/Expo NM) SSCAFCA (Southern Sandoval County Arroyo Flood Control Authority) Class C: ESCAFCA (Eastern Sandoval County Arroyo Flood Control Authority) Sandia Labs (DOE) Class D: Pueblo of Sandia Pueblo of Isleta Pueblo of Santa Ana -EPA Draft Permit (2013) NPDES Permit No. NMR04A000
    5. 5. Challenges to a watershed based permit in the MRG region •The Middle Rio Grande region of New Mexico has political, cultural, geographic and climatic characteristics that are unlike any other urban areas in the country •Low Impact Development (LID) options for stormwater management may be fewer for the MRG • New Mexico is one of the only states without NPDES primacy •There hydrologic and legislative obstacles unique to the region, and to each entity • Some POCs occur naturally as background contaminants • EPA Region 6 (Dallas, TX)
    6. 6. Background Minimum Control Measures 1. Public education and outreach 2. Public participation/involvement 3. Illicit discharge detection and elimination 4. Construction site runoff control 5. Post-construction runoff control 6. Pollution prevention/good housekeeping Stencils created and painted by Tulane University students, Center for Public Service. New Orleans, LA
    7. 7. Discussion and Recommendations - Development of an equitable method of sharing costs of stormwater quality protection measures is difficult for large watersheds, principally those that encompass many stakeholders and a variety of land-use practices Darghouth, Gambarelli, Roux, Styger, Ward. (2008). Watershed managementapproaches ,policies, and operations: lessons for scaling up. The world bank,Washington, DC. -“One of the main attributes of watershed management is the potential to improve the management of externalities resulting from land and water interactions. An externality can be defined as the effect of one party‟s actions that impose a cost or benefit on another party, without that cost or benefit being accounted for in the market” (World Bank, 2001). -Although „cost-sharing‟ and „credit systems‟ were the terms stakeholders were comfortable using under the stipulation of resource allocation, a real cost-benefit/social return on investment analysis was yet to be applied for these methods in the watershed. -A cost-benefit analysis may not be possible until different methods are actually at play
    8. 8. Discussion and Recommendations • The watershed matrix and associated application process - It is important that an entity is able to demonstrate their individuality in categories of „impact‟ and „administrative capacity‟ and infrastructure - Impact for the menu based approach for activity implementation - Administrative capacity and impact combined to show needs for funding
    9. 9. Discussion and Recommendations Joint-powers scenario - It is logical that the BMPs are determined by an entity‟s impact - For credit –trading and cost sharing, sectors should be based on geographic proximity -Under general EPA recommendations for MS4s “In the case of limited capabilities, the permittee can work with neighboring operators of regulated small MS4s, preferably on a watershed basis, to form a shared stormwater management program in which each permittee is responsible for activities that are within individual legal authorities and abilities” (EPA, 2000) - A central agency that administers large fund-raising events and processes applications from individual entities on need basis
    10. 10. Small is better… "If you do it one small watershed at a time, you still have public support. Small size is the advantage. This replaces Big Brother with Joe down the creek.“ Michael Parfit, "Restoration: New Ideas, New Understanding, New Hope," Water: The Power, Promise and Turmoil of North America's Fresh Water. National Geographic Special Edition at pp. 113-114 (November 1993).
    11. 11. EPA Draft Permit (2013) NPDES Permit No. NMR04A000 : Appendix E Cooperative Monitoring Scenario
    12. 12. EPA Draft Permit (2013) NPDES Permit No. NMR04A000: Appendix E Individual Monitoring Scenario
    13. 13. Questions