Promoting the Watershed Approach Using NPDES Permits

摘要

This paper examines four watershed permitting models for their ability to further the goals of the Clean Water Act (CWA) by more effectively controlling point and nonpoint source pollutant loadings. The general benefits and challenges of integrating the watershed approach into the National Pollutant Discharge Elimination System (NPDES) program are first discussed, followed by each of the four watershed permitting models. Separate sections are provided for each of the four models, with a brief description and an assessment of the applications and associated statutory, regulatory, and implementation challenges. Solutions are provided for the identified challenges under each model. The paper concludes by providing more than a dozen recommendations for promoting watershed-based permitting, irrespective of the specific model selected. The recommendations apply to EPA headquarters, EPA regions, and delegated states. The paper closes with a discussion of opportunities for programmatic coordination and integration between the NPDES program and watershed monitoring, characterization and planning, the total maximum daily load (TMDL) process, and trading.