About This Guide

Purpose
This guide is for state and local public works managers who are interested in integrating watershed management into their strategic municipal asset management process.1 Using this guide, these managers can identify municipal infrastructure assets and activities that can adversely affect the surrounding watershed (reducing asset values) and mitigate these potential effects. Using the guide’s step-by-step approach, municipal managers can integrate watershed management into strategic asset management, using current asset management techniques to achieve municipal strategic goals. The guide addresses the key environmental conditions within a municipality’s watershed that influence strategic asset management decisions. The guidance consists of a series of self-assessment forms, which, when completed, create a municipal watershed impact assessment and action plan. This plan, which should be incorporated into the strategic municipal asset management process, includes the following: A description of the designated uses for the municipality’s waterbodies and associated impairments A baseline of municipal land-use categories and activities that can contribute to the waterbody impairments or adversely affect general watershed health A prioritized inventory of discrete municipal activities that can impact the environment and contribute to known impairments within the watersheds

Property owners interested in assessing their property’s impact on the watershed will also find this guide useful.

1

Watershed Impact Assessment Guidance for Public Lands and Facilities

iii

Project-based solutions for cost-effectively mitigating the environmental burden of each activity—with a focus on lowimpact development, bioengineering, and pollution prevention— in an easy-to-use format with all the necessary information (such as justification, benefits, regulatory drivers, appropriate funding sources, cost estimates, schedules, and potential project partners) A baseline from which to monitor progress over time. Note: Watershed assessment approaches vary. Municipal managers can integrate the results of other watershed assessment approaches into their asset management approach as long as the assessment results in a prioritized list of activities and projects derived from a quantitative scoring method.

Organization
Chapter 1 explains how to integrate watershed management into strategic asset management. It begins with an overview of typical municipal asset management issues and their impacts on watersheds. It then examines the strategic asset management approach, explains why watershed management is a critical dimension, and describes how to integrate watershed management into the strategic process. Chapters 2 through 6 contain a series of self-assessment forms and technical information, which give municipal managers the tools necessary to develop a municipal watershed impact assessment and action plan that can be incorporated into their strategic municipal asset management process. Text in sidebars emphasizes action items, tips, and useful tools. Chapter 7 tells how to implement the action plan, track its progress, and update watershed projects as required.

iv

Watershed Impact Assessment Guidance for Public Lands and Facilities

WATERSHED IMPACT ASSESSMENT GUIDANCE FOR PUBLIC LANDS AND FACILITIES
An Approach for Municipal Managers to Integrate Watershed Management and Asset Management Strategies

April 2005

Contents
Preface…. ..............................................................................xi Acknowledgments…. ........................................................... xiii Chapter 1. Integration of Watershed Management and Strategic Asset Management..................................... 1-1
1-1 INTRODUCTION ................................................................................ 1-1 1-2 OVERVIEW OF MUNICIPAL ASSET MANAGEMENT AND STRATEGIC ASSET MANAGEMENT .................................................................. 1-2 1-2.1 Municipal Asset Management ............................................. 1-2 1-2.1.1 HOW MUNICIPAL ASSET MANAGEMENT RELATES TO FINANCIAL MANAGEMENT ................................................... 1-3 1-2.1.2 GASB 34 AND MUNICIPAL ASSET MANAGEMENT SYSTEMS .......................................................................... 1-5 1-2.1.3 PREVENTIVE MAINTENANCE .............................................. 1-9 1-2.2 Strategic Asset Management ............................................. 1-10 1-2.2.1 STEPS OF STRATEGIC ASSET MANAGEMENT .................... 1-11 1-2.2.2 IMPLEMENTING STRATEGIC ASSET MANAGEMENT IN MUNICIPAL MANAGEMENT ................................................ 1-11 1-3 WHY WATERSHED MANAGEMENT SHOULD BE INTEGRATED INTO STRATEGIC ASSET MANAGEMENT .............................................. 1-12 1-3.1 Drivers for Watershed Approach and Assessments ........... 1-13 1-3.2 Impact of Watershed Regulatory Approaches on Municipal Activities............................................................ 1-14 1-3.3 Incorporating Watershed Management into Strategic Assessment Management ................................................ 1-15 1-3.4 Evaluating Watershed Improvement Projects in Strategic Asset Management............................................ 1-17

Chapter 2. Steps to Integrate Watershed Management and Strategic Asset Management.............................. 2-1
2-1 OVERVIEW OF THE MUNICIPAL WATERSHED IMPACT ASSESSMENT PROCESS ................................................................................... 2-1 2-2 OTHER WATERSHED ASSESSMENT PROCESSES ................................ 2-3

Watershed Impact Assessment Guidance for Public Lands and Facilities

v

2-3 LIMITED INTEGRATION WITH STRATEGIC ASSET MANAGEMENT ............ 2-4 2-4 FUTURE RESEARCH TO FURTHER INTEGRATE WATERSHED MANAGEMENT WITH STRATEGIC ASSET MANAGEMENT .................. 2-4

Chapter 3. Identify Your Watershed and Assess Its Current Condition....................................................... 3-1
3-1 INTRODUCTION ................................................................................ 3-1 3-1.1 Using Your Existing Information ........................................... 3-1 3-1.2 Using the Municipal Watershed Impact Assessment Process............................................................................... 3-2 3-2 IDENTIFY MUNICIPALITY’S WATERSHED AND ITS KEY CHARACTERISTICS ...................................................................... 3-2 3-2.1 Form 1—Identify the Watershed Name and Hydrological Unit Code (HUC) ............................................ 3-3 3-2.2 Form 2—Calculate WPS for Each Waterbody Listed on Form 1 ................................................................................ 3-8 3-3 CREATE WATERSHED MAP ............................................................. 3-11 3-4 SELECT GOALS AND PERFORMANCE METRICS ................................. 3-13 3-5 CONCLUSION ................................................................................ 3-14

Chapter 4. Assess Potential Impact of Municipal Land Use and Activities ...................................................... 4-1
4-1 INTRODUCTION ................................................................................ 4-1 4-2 FORM 3—DEVELOP AN INITIAL LIST OF ACTIVITIES ............................. 4-2 4-3 FORM 4—DEVELOP A SUMMARY OF MUNICIPAL LAND USE CATEGORIES (COMPARED WITH WATERSHED AVERAGES OR TARGET VALUES) ....................................................................... 4-2 4-4 FORM 5—IDENTIFY KEY PHYSICAL CHARACTERISTICS AND ACTIVITIES ................................................................................. 4-5 4-5 FORM 6—MUNICIPAL ACTIVITY DATA SHEET ..................................... 4-8 4-5.1 Form 6, Part 1—Describe the Activity, Its Potential Impacts, and Identify the Watershed or Waterbody ............ 4-8 4-5.2 Form 6, Part 2—Quantify the Activity’s Impact and Determine the Total Activity Burden Score ......................... 4-9 4-5.3 Form 6, Part 3—Assess Potential for Pollution Prevention Opportunities .................................................. 4-15

vi

Watershed Impact Assessment Guidance for Public Lands and Facilities

Contents

Chapter 5. Select Migration Projects for High Priority Activities .................................................................... 5-1
5-1 INTRODUCTION ................................................................................ 5-1 5-2 IDENTIFYING BEST MITIGATION EFFORTS OR BEST MANAGEMENT PRACTICES ................................................................................ 5-1 5-2.1 Form 6, Part 4—Determine Project Objectives..................... 5-2 5-2.2 Factors in Developing Project Objectives ............................. 5-4 5-3 SELECTING THE BEST SOLUTION ...................................................... 5-5 5-4 WHAT TO DO IF MULTIPLE MITIGATION EFFORTS ARE POSSIBLE ......... 5-7

Chapter 6. Develop Project Partnerships............................ 6-1
6-1 INTRODUCTION ................................................................................ 6-1 6-2 WHY FORM PARTNERSHIPS?............................................................ 6-1 6-3 WHAT ARE THE STEPS?................................................................... 6-2 6-3.1 Identify Opportunities ........................................................... 6-3 6-3.2 Identify Potential Partners .................................................... 6-3 6-3.3 Develop Partnerships ........................................................... 6-5 6-3.4 Collaborate to Implement Projects ....................................... 6-5 6-3.5 Share Success and Praise with Outside Stakeholders......... 6-5 6-4 WORKING WITH OTHER MUNICIPALITIES ............................................ 6-5 6-5 WORKING WITH REGULATORS .......................................................... 6-5 6-5.1 Working with Regulators During TMDL Determinations ....... 6-5 6-5.2 Working with Regulators to Establish Effluent Trading ......... 6-6

Chapter 7. Implement Solutions and Track Progress ......... 7-1
7-1 PLANNING AND BUDGETING FOR HIGH PRIORITY PROJECTS ................ 7-1 7-1.1 Estimating and Projecting Project Costs............................... 7-1 7-1.2 Integrate Project in Municipal Budget ................................... 7-1 7-1.3 Identify Available Funding Sources ...................................... 7-2 7-1.4 Update Zoning and Ordnance Requirements ....................... 7-2 7-2 SOURCES OF FUNDS FOR IDENTIFIED PROJECTS ................................ 7-2 7-3 OBLIGATING FUNDS, DEVELOPING SCOPES OF WORK, AND LETTING CONTRACTS .................................................................. 7-3

Watershed Impact Assessment Guidance for Public Lands and Facilities

vii

7-4 PRODUCE SUMMARY REPORTS TO TRACK PROJECTS......................... 7-4 7-5 MAINTAINING AND UPDATING YOUR WATERSHED RESTORATION PROJECTS ................................................................................. 7-5

Appendix A Abbreviations Appendix B Laws Affecting Watershed Management Appendix C List of Typical Municipal Activities Appendix D Data Entry Form for Typical Municipal Activities Appendix E References for Best Management Practices Appendix F Sample Forms Appendix G Sample Project Sheet Format

Forms
FORM 1. SUMMARY OF THE MUNICIPALITY’S RECEIVING WATERSHEDS AND ASSOCIATED WATERBODIES ................................................. 3-4 FORM 2. WATERSHED PRIORITY SCORE (WPS): A SENSITIVITY SCORING AND DATA COLLECTION FORM FOR WATERBODIES/WATERSHEDS ...................................................... 3-9 FORM 3. SUMMARY LIST OF MUNICIPAL ACTIVITIES THAT POTENTIALLY AFFECT THE WATERSHED............................................................ 4-3 FORM 4. SUMMARY OF MUNICIPAL LAND USE CATEGORIES ...................... 4-4 FORM 5. SUMMARY QUESTIONS TO IDENTIFY KEY PHYSICAL CHARACTERISTICS AND ACTIVITIES THAT MAY POTENTIALLY IMPACT THE WATERSHED ............................................................ 4-6 FORM 6. MUNICIPAL ACTIVITY DATA ENTRY SHEET ................................ 4-17

Exhibits
1-1 ASSET PERFORMANCE CURVE AND BENEFITS OF PREVENTIVE MAINTENANCE ............................................................................ 1-5 1-2 BASIC FLOW OF AN ASSET MANAGEMENT SYSTEM ............................. 1-8
viii Watershed Impact Assessment Guidance for Public Lands and Facilities

Contents 1-3 ASSESSING BUDGETING ATTRACTIVENESS OF INFRASTRUCTURE INVESTMENTS ............................................................................. 1-9 1-4 ALIGNING STRATEGIC GOALS AND MUNICIPAL ASSET MANAGEMENT .......................................................................... 1-11 1-5 EXAMPLE WATERSHED .................................................................. 1-12 1-6 FEDERAL LAWS, POLICIES, AND PLANS RELATED TO WATERSHED MANAGEMENT AND NON-POINT SOURCE REGULATIONS............... 1-14 1-7 HOW WATERSHED MANAGEMENT IS PART OF STRATEGIC ASSET MANAGEMENT APPROACH ......................................................... 1-15 1-8 INTEGRATING ENVIRONMENTAL BURDEN INTO ASSET MANAGEMENT SYSTEMS ........................................................... 1-17 1-9 BUDGET ATTRACTIVENESS OF WATERSHED IMPROVEMENT PROJECTS ............................................................................... 1-18 3-1 SAMPLE HYDROLOGICAL UNIT CODES ............................................... 3-3 3-2 EXAMPLE EPA SURF YOUR WATERSHED LOCATOR ........................... 3-5 3-3 EXAMPLE OF EPA WATERS MAP .................................................... 3-7 3-4 EXAMPLE EPA TMDL WEBSITE ....................................................... 3-7 4-1 DEFINITIONS OF LIKELIHOOD OF OCCURRENCE OR FREQUENCY OF EVENT CATEGORIES ................................................................. 4-10 4-2 DEFINITIONS OF SEVERITY CATEGORIES FOR POTENTIAL IMPACTS TO SURFACE WATER QUALITY ................................................... 4-11 4-3 DEFINITIONS OF SEVERITY CATEGORIES FOR POTENTIAL IMPACTS TO GROUNDWATER QUALITY...................................................... 4-12 4-4 DEFINITIONS OF SEVERITY CATEGORIES FOR POTENTIAL IMPACTS TO AIR QUALITY ........................................................................ 4-13 4-5 DEFINTIONS OF SEVERITY CATEGORIES FOR POTENTIAL IMPACTS TO QUESTIONS 17–19 .............................................................. 4-13 4-6 DEFINITIONS OF SEVERITY CATEGORIES FOR POTENTIAL IMPACTS TO MUNICIPAL COMPLIANCE BURDEN ......................................... 4-14 4-7 DEFINITIONS OF IMPACT SCORES IN FORM 6.................................... 4-14 5-1 TYPICAL BMPS AND MITIGATION EFFORTS FOR HIGH PRIORITY ACTIVITIES ................................................................................. 5-7 6-1 REGIONAL PARTNERING TEMPLATE ................................................... 6-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

ix

THIS PAGE INTENTIONALLY LEFT BLANK

x

Watershed Impact Assessment Guidance for Public Lands and Facilities

Preface
Over the 30 years since the enactment of the Clean Water and Safe Drinking Water Acts, federal, state and local government agencies, citizens, and the private sector have worked together to make dramatic progress in improving the quality of U.S. surface waters and drinking water. Before these regulations, roughly two-thirds of the surface waters assessed by states were not attaining basic water quality goals and were considered polluted. Some of the Nation’s waters were acting as open sewers, posing health risks; many water bodies were so polluted that traditional uses, such as swimming, fishing, and recreation, were impossible. Through a massive investment of federal, state, and local funds, a new generation of sewage treatment facilities provides “secondary” treatment or better. In addition, sustained federal and state efforts to implement “best management practices” have helped reduce runoff of pollutants from diffuse, or “nonpoint,” sources. Much of the dramatic progress in improving water quality is directly attributable to investment in municipal infrastructure—the land, pipes, and facilities that treat sewage, convey stormwater and sustain healthy habitat. This job, however, is far from over. In 2000, the EPA reported that one or more designated uses are impaired in 39 percent of rivers and streams (miles), 46 percent of lakes (acres), 51 percent of estuaries (square miles), and 78 percent of the Great Lakes (shoreline miles). Furthermore, 14 percent of rivers and 16 percent of lakes did not support their drinking water use designation. Addressing these challenges over the next decade requires more than technologies and regulations—it requires municipal managers to integrate an environmental ethic into all municipal asset management activities. Municipalities face the challenge of improving watershed conditions with limited fiscal resources—funds that are also required to plan, replace aging infrastructure, meet growing infrastructure demands fueled by population growth, rehabilitate urban habitat, and secure their infrastructure against threats. This report presents a framework for municipal managers to integrate environmental stewardship (using a watershed management approach) into its strategic municipal asset management process. Municipal asset management is primarily a financial approach to managing municipal Watershed Impact Assessment Guidance for Public Lands and Facilities xi

infrastructure. Strategic asset management augments the municipal asset management approach by integrating municipality strategic goals, such as environmental stewardship, into the management of its infrastructure asset portfolio. The approach provides a mechanism for municipalities to integrate strategic environmental planning with capital budgeting and infrastructure management. The focus of strategic asset management is to evaluate the cost effectiveness of infrastructure investments. Why focus on cost effectiveness? Optimally, municipalities would have access to unlimited funds to construct or improve any infrastructure asset that would increase public benefit. However, the reality is that municipalities have limited resources for infrastructure investment. The challenge will be to invest these limited resources to generate the greatest net public benefit (that is, to focus on cost effectiveness). The U.S. Environmental Protection Agency (EPA) made this document possible via a grant. We acknowledge the efforts of the many people who participated in the development and completion of this guidance. In particular, we are grateful to the staffs of the American Public Works Association, the Low Impact Development Center, and EPA’s Office of Water.

xii

Watershed Impact Assessment Guidance for Public Lands and Facilities

Acknowledgments
LMI prepared this document under a grant (83050601-0) from the U.S. Environmental Protection Agency (EPA) Office of Water. Research staff from our Facilities and Asset Management Group led this effort. The team was comprised of Emil Dzuray, Julian Bentley, Erica Rohr, Heather Cisar, Lisa Powell, Emily Estes, and Diana Lanunziata. We acknowledge the efforts of the many other people who participated in the development and completion of this document. In particular, we are grateful to Ms. Ann Daniels from the American Public Works Association, Mr. Neil Weinstein from the Low Impact Development Center, and Mr. Robert Goo from the EPA Office of Water. The views, opinions, and findings contained in this document are those of LMI and should not be construed as an official agency position, policy, or decision, unless so designated by other official documentation. Furthermore, LMI makes no warranty, expressed or implied, with the respect to the use of any information, apparatus, method, or process disclosed in this document or assumes any liabilities with respect to the use of, or damages resulting from the use of, any information, apparatus, method, or process disclosed in this document. LMI is a not-for-profit government consulting firm, dedicated exclusively to advancing the management of the government. We help managers in public agencies make decisions that enable immediate action, achieve desired outcomes, and deliver enduring value. We provide a broad range of services across six mission areas: acquisition, logistics, facilities and asset management, financial management, information and technology, and organizations and human capital. (For more information about LMI, visit www.lmi.org.)

Watershed Impact Assessment Guidance for Public Lands and Facilities

xiii

THIS PAGE INTENTIONALLY LEFT BLANK

xiv

Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter Chapter 11 Integration of Watershed Management and Strategic Asset Management

1-1 Introduction
Municipal managers constantly struggle to balance the conflicting goals of investing in municipality improvements and maximizing future asset value under the restrictions of limited budgets. How can municipal managers successfully budget to enhance current municipality welfare and increase long-term asset value? An approach that integrates watershed management with strategic asset management solves the dilemma of concurrently improving public services, enhancing local environmental conditions, and investing in the long-term value of the municipality assets. Furthermore, municipal managers must achieve these objectives while cost-effectively complying with numerous federal, state, and local environmental laws and regulations. This management role has become increasingly difficult because requirements of major environmental laws have increased exponentially over the past few decades while municipal environmental budgets have remained flat. Specific revisions to the rules promulgating the Clean Water Act (CWA) and Safe Drinking Water Act (SDWA) have the potential to not only result in more stringent limits for existing environmental permits, but to impose operational limits on currently unregulated activities that adversely affect the quality of surface water, groundwater, habitat, or air. This guide provides a consistent, cost-effective decision-making approach that state and local managers can use to integrate watershed management into their strategic municipal asset management process. It enables them to identify municipal infrastructure assets and activities that can adversely affect the surrounding watershed (reducing asset values) and to find ways to mitigate the effects.

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-1

1-2 Overview of Municipal Asset Management and Strategic Asset Management
Municipalities share a similar mission: to proactively enhance the health, safety, and welfare of current and future generations through responsible stewardship of municipality infrastructure, development, and maintenance functions. Municipalities endeavor to
create safe and livable communities,

What is infrastructure?
Long-lived, normally stationary capital assets—such as roads, bridges, tunnels, drainage systems, water and sewer systems, dams, and lighting systems— preserved for significantly more years than most capital assets. Buildings, which have a shorter service life, are not considered infrastructure, except those that are an ancillary part of an infrastructure facility (such as a wastewater treatment building).

fuel economic growth, build cohesive communities, support human growth and development, develop public infrastructure systems that adequately and efficiently serve communities, and enhance and protect the environment.

Achieving these goals requires that municipalities simultaneously optimize three independent asset dimensions: condition, functionality, and environmental impact. Few would argue that current management approaches attempt to optimize asset condition and functionality. In fact, most infrastructure investments are made using a purely financial asset management approach. Most current asset management techniques, however, fail to integrate municipal strategic goals, including environmental conditions, in the decision-making process. Integrating watershed management into strategic asset management enables municipalities to simultaneously optimize condition, functionality, and environmental impact; as a result, they can concurrently optimize financial, environmental, health, community, and service aspects of infrastructure investments. However, before we can show how the watershed assessment approach can be integrated into a strategic asset management approach, we need to review both traditional asset management and strategic asset management approaches. 1-2.1 Municipal Asset Management Municipalities rely on an extensive infrastructure, consisting of transportation networks, power supply, water supply, drainage, sewerage, solid waste management services, and other assets. These assets represent an immense investment built over many generations, made to fulfill anticipated benefits such as increased productivity and enhanced citizen welfare. Municipalities face the constant challenge of maximizing net public benefit with a limited amount of resources.

1-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management The concept of asset management is in its infancy, with varying definitions. The American Public Works Association’s (APWA’s) asset management task force created a common asset management definition, “to efficiently and equitably allocate resources amongst valid and competing municipal asset goals and objectives,”1 from its review of various asset management methods. The APWA further defines asset management to include the following:
Efficiently allocate funds: The allocation of funds must be efficient within a particular class of assets (like roads or bridges), and within the entire reservoir of assets being managed (roads versus water networks versus buildings versus parks versus…). The latest engineering and economic principles, like value engineering and life cycle cost analysis or similar concepts are part and parcel of the asset management policy. Equitably allocate funds: The allocation of funds must be equitable as well as efficient. In this context, equitability refers mostly to constraints, limitations, or orientations that an administration needs to impose on the process in order to avoid being faced with solutions that fail to take in all factors, that are beyond its means, or that are unrealistic or unacceptable. In this context also, equitability allows for the consideration of expressed user needs and of any particular overriding one-time need. Valid and competing needs: This refers to all the needs of a community. Needs are valid if they are determined by individual management systems or if they are expressed to and accepted by the managers through any recognized approval process. The needs can be past unsatisfied needs (deferred maintenance), current maintenance needs, current capital improvement needs validated by a value engineering analysis, or future maintenance needs as determined in life cycle cost analyses. They are linked directly to the service levels demanded by the community. The needs are competing against one another in each class of assets as well as competing between different classes of assets. Even when funding is not an issue, competition must still exist to ensure that the extra dollars are spent in the most efficient way possible.2

What is asset management?
The APWA’s definition of asset management is to efficiently and equitably allocate resources amongst valid and competing municipal asset goals and objectives.

1-2.2 How Municipal Asset Management Relates to Financial Management Asset management focuses on the evaluation of the cost-effectiveness of infrastructure investments. Optimally, municipalities would have
N. Danylo and Andrew Lemer, Asset Management for the Public Works Manager: Challenges and Strategies: Findings of the APWA Task Force on Asset Management, August 31, 1998. Available from www.apwa.net/documents/resourcecenter/ampaper.rtf. 2 See note 1.
1

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-3

access to unlimited funds to construct or improve any infrastructure asset that would increase public benefit. However, the reality is that municipalities have limited resources. The challenge is to invest the limited resources to generate the greatest net public benefit (that is, focus on cost-effectiveness). The optimization of net public benefit is commonly measured by asset valuation expressed in two ways, functionality and condition: Functionality is the net benefit to the public of the asset’s function. Functionality measures the asset’s maximum potential value and depends on the public use of the asset. Not all assets within the same class have similar functional value. For example, a critical thoroughfare road has a higher functional value than a rarely used rural road. Condition is the ability of the asset to provide function over time. Condition measures the percentage of the maximum functional value provided during the asset’s life. It can depend on the level of preventive maintenance. The asset performance curve, shown in Exhibit 1-1, graphs the relationship between asset performance, condition, and preventive maintenance, as well as the benefits of preventive maintenance. As the asset ages, its condition deteriorates from requiring preventive maintenance to more costly maintenance and rehabilitation. Once the condition reaches a minimum level, the asset is unusable and requires costly reconstruction. However, if the asset receives preventive maintenance, the rate of deterioration decreases, thereby extending its life.

1-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management

Exhibit 1-1. Asset Performance Curve and Benefits of Preventive Maintenance

Source: Federation of Canadian Municipalities and National Research Council Canada, National Guide to Sustainable Municipal Infrastructure: Innovations and Best Practices

1-2.3 GASB 34 and Municipal Asset Management Systems Accurately quantifying the public benefit of infrastructure is a complex task, one of the greatest challenges in asset management. For example, there is no simple financial analysis for placing a value on the net benefit of the presence of a sewer system or road. In June 1999, the Government Accounting Standards Board (GASB) established GASB Statement 34 (GASB 34) to assist in this effort. The rule requires municipalities to account for the value of major capital assets (including bridges, roads, water systems, and dams) in their financial statements. GASB 34 serves as the basis for today’s municipal asset management systems. GASB 34 provides two methods for reporting infrastructure assets, depreciation and the modified approach: Depreciation involves completing an extensive inventory of assets, including their costs and the dates when they were created or purchased. Each asset’s value is then calculated on the basis of depreciation over the estimated useful life. The method does not value assets on the basis of condition.

Depreciation approach
Reduces asset value over the estimated useful life. Does not value assets based on condition. Focuses on addressing infrastructure needs through new infrastructure development. Often fails to address life-cycle costs of maintaining, operating, and renewing assets.

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-5

The modified approach incorporates condition assessments of infrastructure assets and includes the following requirements: Maintain an up-to-date inventory of eligible infrastructure assets. Assess the condition of the eligible infrastructure assets every 3 years and summarize the results using a measurement scale. Annually estimate the costs to maintain and preserve the eligible infrastructure assets at the condition level established and disclosed by the government entity. Under the modified approach, the municipality reports the actual costs of maintaining and preserving infrastructure assets at a determined condition level instead of calculating depreciation charges. The depreciation method, the easier of the two approaches to implement, instead focuses on replacing or developing new infrastructure to address infrastructure needs rather than addressing the life-cycle costs of maintaining, operating, and renewing these infrastructure assets. The APWA endorses the modified approach since it enables municipalities to incorporate the benefits of maintenance into municipal asset valuation.3 Exhibit 1-2 outlines the basic flow and components of an asset management system, which are as follows: 1. Inventory of Infrastructure Assets. The first stage is to conduct an inventory of infrastructure assets. Data collected include location, construction cost, physical characteristics, usage information, accident history, and maintenance performed. 2. Infrastructure Asset Valuation. Next, a municipality must place a value on the asset. Valuation begins by assessing the condition of all infrastructure assets. GASB 34 requires municipalities to do so using a replicable measurement method every 3 years. The municipality also must estimate the useful asset life. For each year of the infrastructure’s life, the net public benefit of the asset is determined from the current predicted condition levels and planned maintenance. Asset value is then calculated as the sum of these annual benefits discounted at the cost of capital. Asset values are calculated based on functional value and condition. The modified approach uses a productivityrealized asset valuation method in which the asset value is calculated as the “net present value of the benefit stream for
American Public Works Association, APWA Policy Statement—GASB 34, November 2000.
3

1-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management the remaining service life.”4 The net present value captures the functional value over the lifetime of the asset as well as the benefits of maintenance on improving the function of the asset and extending its life (reflected in condition). 3. List of Potential Infrastructure Improvements. At the top of any municipality’s wish list is having the resources to complete an infrastructure improvement that has a “return on investment” greater than the capital cost. However, municipalities, faced with limited resources, must develop a list of potential infrastructure improvements that best allocates their limited funds. The list includes all potential new infrastructure investments as well as asset maintenance, retrofitting, or modifications not currently planned or funded. 4. Resource Allocation Model. Employing a resource allocation model enables municipalities to rank potential infrastructure investments and establish funding requirements. The resource allocation model serves as the heart of municipal asset management and incorporates the municipality’s key asset management decision-making method. The primary inputs to the model are infrastructure improvement cost estimates, current and future asset condition estimates, and current and future functional value estimates. The model calculates a net present value of each infrastructure improvement using (1) the annual cost expenses for the improvement, (2) the estimated annual benefits (calculated using the difference of the current and future asset values), and (3) the predicted current and future asset life. The most important output is a ranking of the potential infrastructure improvements based on return on investment and total cost. These variables are the primary input to the infrastructure budgeting process. 5. Infrastructure Budget. Though decision-making logic is incorporated in the research allocation model, decisions are ultimately made through infrastructure budgeting. Selecting infrastructure investments for funding is largely a subjective process. Though return on investment and total cost provide decision-making criteria, there is no exact science to developing an infrastructure budget. On the basis of these criteria, we have developed nine primary categories of infrastructure investments. Exhibit 1-3 shows the attractiveness to municipalities for funding infrastructure investments within these categories.

Sue McNeil, “Asset Management and Asset Valuation: The Implications of the GASB Standards for Reporting Capital Assets,” Proceedings of the Mid-Continent Transportation Symposium, 2000.

4

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-7

Exhibit 1-2. Basic Flow of an Asset Management System

inventory of Infrastructure Assets

Infrastructure Asset Valuation

Current Asset Condition

List of Potential Infrastructure Improvements

Current Asset Functional Value

Forecast Asset Condition Improvement

Resource Allocation Model
Return on Investment

Forecast Asset Functional Value Improvement

- Net Asset Value Improvement - Total Infrastructure
Improvement

Infrastructure Budget

1-8

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management

Exhibit 1-3. Assessing Budgeting Attractiveness of Infrastructure Investments
Return on investment 1 2 3 4 5 6 7 8 9 High High High Medium Medium Medium Low Low Low Total cost Low Medium High Low Medium High Low Medium High Budgeting attractiveness High: Almost always funded; very cost-effective High: Generally funded, except when budgets are very tight Medium/Low: Although these investments have high returns, limited resources mean only a handful can be funded High: Generally funded, except when budgets are very tight Medium: Most subjective of budgeting decisions; depends on attractiveness of other investments Low: High cost, high return investments are likely funded instead of these Medium/Low: Projects with higher returns are funded Low: Projects with higher returns are funded Low: Projects with higher returns are funded

1-2.4 Preventive Maintenance Much of the municipal core infrastructure is aging, overused, and lacking investment in maintenance (repair, rehabilitation, and replacement)—all of which severely strain the assets. To add to the problem, citizens demand additional new infrastructure to address growth. Although municipalities attempt to maximize the returns on their infrastructure investments, their asset management practices often hinder meeting these objectives. The primary impediment is budgeting. Few municipalities can split their capital budgets between new projects and renewal/maintenance. As a result, they fuel inefficiency, investing in costly new infrastructure while failing to address asset deterioration. A solution to the problem, in lieu of additional resources, is to perform preventive maintenance. Preventive maintenance is a best management practice that optimizes the public’s benefit from infrastructure investment. Preventive maintenance is the most cost-effective approach to increasing asset values. It reduces the rate of asset condition deterioration over time, extends the asset life, and increases functional value. Municipal asset management must shift from a “dire need” maintenance approach to a preventive system of maintenance and renewal.5 Preventive maintenance focuses on providing sustained value to citizens at the lowest cost over the asset life cycle.

CartêGraph Systems, Inc., Getting Started in Public Works Asset Management, 2004. Available from www.cartegraph.com.

5

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-9

Other asset management best practices include understanding the requirements of the citizens, understanding the cost of sustaining the value of assets for at least 15 years, understanding demand for new assets and services, constructing new assets and services only with appropriate allocations of real operating costs, and selecting an optimal strategy for the municipality, ratepayers, and social community. 1-2.5 Strategic Asset Management

Strategic asset management
Strategic asset management augments the municipal asset management approach by integrating municipality strategic goals into the management of its infrastructure asset portfolio.

Asset management is a financially based approach to infrastructure investment. Although effective at managing the economic health of a municipality, the approach is only loosely linked to serving the municipality goals, that is, optimizing citizen welfare. Thus, the approach cannot achieve strategic goals because municipalities often fail to evaluate infrastructure investments on the basis of their alignment to municipal strategy. They fail to incorporate in funding decisions the ability of the asset to (1) create safe and livable communities, (2) build cohesive communities, (3) support human growth and development, (4) adequately and efficiently serve communities, and (5) enhance and protect the environment. Strategic asset management augments the municipal asset management approach by integrating municipality strategic goals into the management of its infrastructure asset portfolio. It provides a mechanism for municipalities to integrate long-term strategic planning with capital budgeting and infrastructure management. The focus is on the evaluation of the cost-effectiveness of infrastructure investments. Exhibit 1-4 presents an evaluation of the financial and strategic performance of municipalities based on different management approaches. Municipalities that focus on achieving strategic goals through a poor or non-existent asset management approach fail to optimize the financial performance of asset investments. Similarly, municipalities that make infrastructure investment decisions solely on the basis of financial returns fail to realize their strategic goals. Only the best performing municipalities employ a strategic asset management approach to align infrastructure management and investment with municipal strategic goals.

1-10

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management

Exhibit 1-4. Aligning Strategic Goals and Municipal Asset Management
Aligned

Alignment with Strategic Goals

Poor Financial Performance

Best Performing Municipalities

Poor Financial and Strategic Performance

Little Strategic Direction

Not Aligned
None

Best Practices

Asset Management

1-2.6 Steps of Strategic Asset Management Strategic asset management consists of the following four steps: 1. Evaluate projects. The municipality evaluates how the project results align with the municipal goals (mission need). 2. Perform a cost analysis. The municipality analyzes the cost of the projects, evaluating the design, implementation, and operating and maintenance costs. 3. Quantify and qualify the project benefits. It quantifies and qualifies the benefits of the project in improving municipality asset value (the difference between value before and after the implementation of the project). 4. Select projects. The municipality selects projects on the basis of the greatest net financial benefit and associated mission. 1-2.7 Implementing Strategic Asset Management in Municipal Management Critical to the implementation of strategic asset management is an asset management system that integrates strategic goals into final decisions. Current asset management systems focus on optimizing asset condition and functionality. The goal is to maximize the net present value of the benefit streams from infrastructure investments, rather than to achieve strategic goals.

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-11

Municipalities can concurrently manage the financial viability of infrastructure investments and strive to achieve strategic goals. The implementation of strategic asset management requires them to integrate variables that measure the realization of strategic goals into asset management decisions. They can do so by modifying current asset management systems to include additional variables in their evaluation of infrastructure investments. For example, when evaluating the investment in constructing a bridge, the asset management system should provide the project’s net economic benefit as well as different measures of its alignment with a number of strategic goals. The manager weighs both variables in making an investment decision.

1-3 Why Watershed Management Should Be Integrated into Strategic Asset Management
Watershed management is the most comprehensive approach to environmental stewardship. A watershed is simply the land that water flows across or through on its way to a common stream, river, or lake, as shown in Exhibit 1-5. A watershed can be very large (thousands of square miles that drain to a major river, lake, or ocean) or very small (20 acres that drain to a pond). A small watershed that nests inside of a larger watershed is referred to as a subwatershed. Watersheds, geographical areas defined by natural hydrology, are the most logical basis for managing the impacts of human activity on the environment (air, water, and habitat). Focusing on the natural resource, rather than the specific sources of pollution, enables municipalities to evaluate the overall conditions in a geographic area and manage the stressors that affect those conditions. Exhibit 1-5. Example Watershed

What is a watershed?
A watershed is simply the land that water flows across or through on its way to a common stream, river, or lake. Watersheds can be any size, from a few acres to thousands of square miles.

Watershed boundary

River mouth Groundwater recharge (aquifer)

1-12

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management Watershed management is a critical dimension of strategic asset management. Minimizing environmental impact (i.e., watershed management) and enhancing local environmental conditions are integral to achieving one of the key municipality strategic goals: enhancing the welfare of future generations by maximizing long-term asset value. 1-3.1 Drivers for Watershed Approach and Assessments Watershed management approaches are particularly important to municipal managers. Over the past 10 years, municipalities have faced increasingly complex regulations as the U.S. Environmental Protection Agency (EPA) has revised much of its legislation. Working to better integrate watershed approaches, the EPA revised the Clean Water Act, Safe Drinking Water Act, and other regulations concerning water quality, effluent standards, source water protection standards, and stormwater management. These changes, along with the move by regulators to issue permits by watershed, require municipal managers to reevaluate how municipal activities impair water resources and to develop action plans to prevent or correct the identified impairments. The main compliance drivers behind adopting a watershed approach and completing watershed assessments to manage water issues are as follows: Clean Water Act. National pollutant discharge elimination system (NPDES), total maximum daily loads (TMDL), spill prevention control and countermeasures (SPCC), wetland 404 permits and mitigation, sludge disposal or reuse, and point and non-point stormwater management programs. Safe Drinking Water Act. Source water assessment and protection program (which includes wellhead protection), and underground injection control (UIC) program. Coastal Zone Management Act. Required the 29 states with federally approved Coastal Zone Management Act programs to develop coastal NPS programs. Exhibit 1-6 shows the relevant federal laws, policies, and plans related to watershed management. Appendix B summarizes the key federal laws and policies governing water resources that provide the basis for watershed protection activities. assess a waterbody’s ability to meet its intended use, determine the pollutants and potential sources of impairments, incorporate assessment results into a plan aimed at achieving water quality objectives, and foster collaboration with all landowners in the watershed

What is watershed management?
A framework to

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-13

Exhibit 1-6. Federal Laws, Policies, and Plans Related to Watershed Management and Non-Point Source Regulations Category
Federal laws

Title
Clean Water Act (CWA) and amendments Part 130 of Title 40 of the Code of Federal Regulations Water Quality Planning and Management Safe Drinking Water Act (SDWA) and amendments Coastal Zone Management Act of 1972 (CZMA) Clean Air Act (CAA) and amendments Comprehensive Environmental Restoration, Compensation and Liability Act (CERCLA) Emergency Planning and Community Right-to-Know Act (EPCRA) Endangered Species Act (ESA) Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Resource Conservation and Recovery Act (RCRA) Toxic Substances Control Act (TSCA)

Policies and plans

EPA’s National Water Program Strategic Plan 2004 -2008, April 2004 EPA’s Watershed-Based NPDES Permitting Policy, January 2003 EPA Memo, Committing EPA's Water Program to Advancing the Watershed Approach, December 2002 EPA’s Draft Watershed-Based NPDES Permitting Implementation Guidance, August 2003

1-3.2 Impact of Watershed Regulatory Approaches on Municipal Activities

What is a TMDL?
A written quantitative analysis of an impaired waterbody, which is established to ensure that the waterbody’s designated uses are attained and maintained in all seasons.

The CWA’s TMDL and stormwater regulations are the primary regulations directing the development of watershed management policies. However, in their efforts to restore an impaired waterbody, regulators are increasingly using the broad scope of these regulations, among others: Modifying a municipality’s NPDES, RCRA, or CAA (in the case of CAA, it would be pollutants found in a waterbody that are directly related to air deposition) discharge permits to require monitoring or limits for new pollutants, reduce discharge limits of existing pollutants, or prohibit discharges of particular pollutants Requiring stormwater control devices that provide flow control, treatment, or both

1-14

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management Requiring a permit for or modification of activities that may be generating non-point sources of pollution and are not typically covered under the NPDES program Requiring sites to implement best management practices (BMPs) for construction, agriculture, timber operations, and other ground-disturbing activities Implementing land use controls or restrictions on activities located on properties surrounding waterbodies Requiring development of additional riparian buffer zones, stream bank stabilization, or additional wetlands Restricting the site use of surface water and groundwater. 1-3.3 Incorporating Watershed Management into Strategic Assessment Management Watershed management is a critical dimension of strategic asset management (Exhibit 1-7); it is integral to achieving one of the key municipality strategic goals: enhancing the welfare of future generations by maximizing long-term asset value. Ignoring the environmental impact of an asset decision may only have a minimal impact on the value of the municipality assets in the short term. However, in the long term, a degraded surrounding environment can reduce asset value and impede an asset’s functional use. Exhibit 1-7. How Watershed Management Is Part of Strategic Asset Management Approach

Current municipal asset management techniques fail to incorporate other strategic goals in infrastructure investment decisions

Strategic Goal: Optimize return on investment (i.e., minimize costs)

Strategic Goal: Optimize environmental condition

The watershed assessment approach addresses environmental condition as part of the entire strategic management approach

Strategic Goal: Support human growth and development

Strategic Goal: Create safe and livable communities

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-15

Environmental impact factors into all four strategic asset management steps. First, enhancing and protecting the environment is one of the pillars of the municipality mission. Second, the cost analysis must include quantifying the financial consequences of environmental degradation. Finally, projects that improve environmental conditions improve asset value. Net financial impact would be incomplete without integrating environmental condition. Current management approaches attempt to optimize asset condition and functionality. They do not address minimizing the environmental impact. Achieving environmental strategic goals requires municipalities to simultaneously optimize three independent asset dimensions: condition, functionality, and environmental burden. By concurrently evaluating the environmental impacts (as measured by environmental burden) and financial performance (as measured by functional value and condition), municipalities can manage infrastructure investments to reach both financial and environmental strategic goals. Environmental burden measures the impact of an infrastructure investment on the receiving environment. Infrastructure investments where the main purpose is not to improve the environment (such as roads and bridges) have a negative environmental burden, and investments designed to improve the receiving environment have a positive environmental burden. Environmental burden fits nicely within the current asset management system, integrated as a component of asset condition. This technique reduces the value of infrastructure investments that have a negative impact on the receiving environment. This approach also allows municipalities to evaluate funding for projects designed only to improve environmental condition compared with other infrastructure investments (weigh the benefits environmental projects generate from improvements to condition compared with project costs). Exhibit 1-8 shows the impacts of integrating environmental burden on each component of the asset management system.

1-16

Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management

Exhibit 1-8. Integrating Environmental Burden into Asset Management Systems Component
Inventory of infrastructure assets

Current system
List all infrastructure assets and associated data managed by the municipality, including location, construction cost, physical characteristics, and usage Conduct condition assessments of all infrastructure assets and calculate net present value of asset benefits over useful life List all infrastructure improvements that have a return on investment greater than the cost of capital Rank the potential infrastructure improvements on the basis of return on investment and total cost Select infrastructure investments for funding

Impact of integrating environmental burden
Collect environmental condition (that is, watershed condition) data as part of infrastructure inventory management system Factor environmental burden into asset condition calculation

Infrastructure asset valuation

List of potential infrastructure improvements Resource allocation model Infrastructure budget

Add environmental condition improvement projects to list Incorporate environmental burden as a variable in the model to evaluate the effects of environmental condition on investment returns Integrate environmental impacts in budgeting decisions

1-3.4 Evaluating Watershed Improvement Projects in Strategic Asset Management Evaluation of watershed improvement projects begins with a baseline valuation assessment. Municipal managers calculate baseline asset value based on optimal functional value discounted by condition, as measured by both watershed condition (i.e., environmental burden) and ability of the asset to provide functional use. Municipal managers then evaluate and rank potential watershed improvement projects based on two factors, return on investment and total project cost. Return on investment is calculated using the increase in future asset value (from improved environmental burden) measured against the total project cost. Finally, municipal managers select watershed improvement projects for funding. Although the process is often subjective, return on investment and total cost are the primary decision-making criteria. Exhibits 1-3 and 1-9 outline the attractiveness for funding projects based on return on investment and total cost.

Watershed Impact Assessment Guidance for Public Lands and Facilities

1-17

Exhibit 1-9. Budget Attractiveness of Watershed Improvement Projects
Low

High Priority Projects
Total Project Cost

Secondary Priority Projects

High

Lower Priority Projects
Low or Negative High

Return on Investment

1-18

Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter 2 Steps to Integrate Watershed Management and Strategic Asset Management
2-1 Overview of the Municipal Watershed Impact Assessment Process
The remainder of this guide describes the steps you can take to integrate watershed management into your strategic asset management process. These steps, the Municipal Watershed Impact Assessment Process, are organized in an easy-to-use format. Using this guidance, you can assess the impact of your municipality on the local waterbodies and develop a prioritized list of solutions that can be integrated into your municipality’s strategic asset management goals and process. The six major steps of the Municipal Watershed Impact Assessment Process are as follows: Step 1. Establish and refine strategic asset management goals. Review current municipal goals, laws, and regulations and any watershed restoration action plans. You will use this information to establish or refine integrated goals and associated performance objectives. Step 2. Calculate the watershed condition score for each watershed using Forms 1 and 2. Assess the condition and vulnerability of watersheds, subwatersheds, and waterbodies; determine designated uses; and identify impairments of concern. You complete Forms 1 and 2 to identify and prioritize the watersheds, subwatersheds, waterbodies, and regional watershed partners located on or along the municipal boundary on the basis of current conditions, future vulnerability, and compliance requirements. The guide walks you through the process of documenting the designated uses and impairments of concern. At the end of

Watershed Impact Assessment Guidance for Public Lands and Facilities

2-1

this step, you will have developed a watershed priority score (WPS) for each significant waterbody on or surrounding your municipality. Step 3. Calculate the total burden score for each significant infrastructure asset or municipal activity using Forms 3, 4, 5, and 6 (Parts 1, 2, and 3). Assess the potential impact of municipal activities. This part of the process is divided into three sections: 1. Using the checklist of typical municipal activities found in Appendix C, identify those in your municipality that may contribute to the impairments of concern. 2. Complete Form 3 to create a baseline of municipal activities by land uses. Use Form 4 to compare your municipality’s land use with that of the watershed. Use Form 5 to summarize the municipality’s land-use characteristics. 3. For each activity, use Form 6, Parts 1–3, to calculate the activity’s impact score, and to create a total activity burden score (TABS). The TABS is a sum of the activity impact score (AIS) and WPS. The guide pays particular attention to the amount of impervious surfaces in your municipality. Step 4. Identify cost-effective solutions to mitigate high priority impacts using Form 6 (Parts 4 and 5). Identify whether the municipality needs additional projects to mitigate high priority activities or land-use conditions. Compare the prioritized list of activities and their associated impairments with available BMPs. This guide contains references to sources of cost-effective BMPs and innovative projects that can help you mitigate an activity’s potential impact on the watershed. Integrate project criteria into the municipality strategic asset management framework to rank projects. Compare improvement in asset condition (and value) and project costs to select the most cost-effective projects. Develop a project description, justification, and cost. Track funding requests and the project through completion. Step 5. Identify partnerships and funding sources using Form 6 (Part 6). Identify and develop partnerships with other stakeholders to implement the selected BMPs and other watershed restoration efforts that reduce the municipality’s impact on the watershed. Form 6 allows you to list partners, agreements, benefits, addresses, and points of contact for tracking purposes. This guide provides links to groups active in watersheds around the country as well as types of groups that may provide assistance and support. Chapter 6 contains a partnership template for tracking regional and project partners.

2-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Steps to Integrate Watershed Management and Strategic Asset Management Step 6. Implement solutions, track progress, and reassess as part of strategic asset management. Incorporate the solutions into your municipality’s strategic asset management decisions, implement the identified solutions, track their progress, and update the plan and project requests as required to adjust management direction as new information becomes available. The majority of the information needed to complete the Municipal Watershed Assessment Process should be readily available from existing records and federal or state regulatory agencies. In particular, the EPA has created a database and interactive map site containing a wealth of information about the nation’s watersheds. The database is available through the EPA’s Surf Your Watershed website at http://cfpub.epa.gov/ surf/locate/index.cfm. It also has created the Watershed Assessment, Tracking & Environmental Results (WATERS) website, located at http://www.epa.gov/waters/enviromapper/index.html. WATERS is a tool that unites water quality information previously available only on individual state agency homepages and at several EPA websites. It is a web-based geographic information system (GIS) that shows watershed delineations, waterbodies, permitted discharges to all media, TMDL status, and water quality standards. You can quickly identify the status of individual waterbodies and generate summary reports on all waters that influence your municipality.

2-2 Other Watershed Assessment Processes
Other watershed assessment processes available for municipal managers include the following: The Watershed Protection Audit establishes a baseline of current strategies and practices within a municipality’s watershed. The audit can be used to determine the watershed tools currently available in a watershed. The audit is located at http://www.cwp.org. The Watershed Vulnerability Analysis provides guidance on delineating subwatersheds, estimating current and future impervious cover, and identifying factors that would alter the initial classification of individual subwatersheds. This guidance outlines a basic eight-step process for creating a rapid watershed plan for either a large watershed or a jurisdiction. The Watershed Vulnerability Analysis is located at http://www.cwp.org. The Retrofit Assessment includes the Eight Steps to Stormwater Retrofitting, which outlines the eight steps of performing a retrofit inventory. This involves examining existing stormwater management practices and pinpointing locations that might benefit from additional practices. Details

Watershed Impact Assessment Guidance for Public Lands and Facilities

2-3

on retrofit implementation are included. Assessment is located at http://www.cwp.org.

The

Retrofit

The Codes and Ordinances Worksheet is a simple worksheet used to compare local development rules in a community with the model development principles outlined in the Better Site Design. The worksheet is located at http://www.cwp.org.

2-3 Limited Integration with Strategic Asset Management
Although this Municipal Watershed Impact Assessment Process is designed to be integrated into your strategic asset management process, the integration is not seamless. Municipalities may use the outputs of the process, environmental burden improvement and project costs, as inputs to their strategic asset management systems. These inputs are then used in those systems to evaluate and rank projects based on “return on investment” (as calculated by increase in long-term asset value) and total cost (see Exhibit 1-8). The strategic asset management approach is in its infancy, especially the use of condition assessments to value assets. The lack of a standardized asset valuation method that incorporates environmental (and watershed) burden complicates a seamless integration of the process with strategic asset management. Over the next few years, the strategic asset management approach will mature and standardized systems are expected to be available for implementation by municipalities. At that time, we suggest updating the Municipal Watershed Impact Assessment Process to seamlessly integrate it with your strategic asset management process.

2-4 Future Research to Further Integrate Watershed Management with Strategic Asset Management
We suggest further research into incorporating environmental burden into strategic asset management systems. As more municipalities become familiar with GASB 34 and its modified approach, we expect techniques for valuing assets on the basis of environmental burden to improve and become more available. More research is needed to determine the best method to factor environmental burden into asset condition (and valuation) calculations. Once a standardized method is established for valuing assets on the basis of environmental burden, we suggest revising the Municipal Watershed Impact Assessment Process to include asset valuation in evaluating watershed projects. In addition, the process may be updated for integration with any new standardized strategic asset management tools that become available to municipalities.

2-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter 3 Identify Your Watershed and Assess Its Current Condition

3-1

Introduction

Summary
This chapter walks you through the completion of Forms 1 and 2. The information contained in Forms 1 and 2 enables you to identify your watershed and its characteristics.

In this chapter, you learn to identify your municipality’s watersheds and determine their current conditions by completing Forms 1 and 2. It also presents an approach for developing goals and selecting key performance metrics to measure progress. The instructions help you identify watershed names and hydrological unit codes (HUCs); create a map of the watershed and its boundaries; prepare a list of regulatory and local designated uses, impairments of concern, and an overall watershed condition score using available information; calculate a condition score for each receiving waterbody; identify key stakeholders active in the watershed; and identify key goals and performance metrics to guide the prioritization of projects and enable the tracking of progress over time. 3-1.1 Using Your Existing Information In addition to the one this guide describes, other methods and sources are available for determining the conditions of your watershed: Environmental office documentation. The municipal environmental office may have already identified the watersheds and assessed the conditions of the waterbodies to which your property drains. Watershed vulnerability analysis. This analysis provides guidance on delineating subwatersheds, estimating current and future impervious cover, and identifying factors that would

I already have my watershed information
You may have already identified the watersheds and waterbodies to which your municipality drains. If so, ensure you have all of the information in Forms 1 and 2 and that you have quantitatively scored their condition.

Watershed Impact Assessment Guidance for Public Lands and Facilities

3-1

alter the initial classification of individual subwatersheds. The document outlines a basic eight-step process for creating a rapid watershed plan for either a large watershed or jurisdiction. It is available at http://www.cwp.org/Vulnerability Analysis.pdf. Watershed protection audit. This audit establishes a baseline of current strategies and practices within the watershed. By understanding the current state of development, watershed groups can assess strategies, practices, strengths, and weaknesses and can better plan future efforts. This document can help watershed organizations audit the watershed protection tools currently available in their watershed. It is available at http://www.cwp.org/Community_Watersheds/Watershed Protection_Audit2.pdf. If you already have the watershed background information, you have already begun the first step of the watershed assessment process. You need to ensure you have all of the information in Forms 1 and 2 and that you have quantitatively scored the condition of your municipality’s receiving waterbodies. You can convert your information into Forms 1 and 2 or leave them in their original format. 3-1.2 Using the Municipal Watershed Impact Assessment Process The remainder of this chapter walks you through the steps for completing Forms 1 and 2. Complete Forms 1 and 2 by relying on existing information and tools primarily available in municipal documents and from EPA, state, and local regulators. Form 1 enables you to create a summary of key watershed information—including the name of the watershed, its HUC, the significant municipal waterbodies, and their condition and vulnerability scores—using existing information related to watershed indicators. Complete a Form 2 for each significant waterbody identified in Form 1, and then use the results of Form 2 to select key performance metrics to serve as the baseline for measuring your municipality’s progress.

3-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Identify Your Watershed and Assess Its Current Condition

3-2 Identify Municipality’s Watershed and Its Key Characteristics
EPA, states, and local groups have established extensive online tools to help you identify the watershed in which your municipality resides and assess its characteristics. The two most relevant sites are EPA’s Surf Your Watershed site at http://cfpub.epa.gov/surf/ locate/index.cfm and EPA’s WATERS website at http://www.epa.gov/waters/. The WATERS system is a tool that unites water quality information previously available only on individual state agency homepages and at several EPA websites. It can also be used to generate summary reports on all waters of a state. Both applications provide links to a GIS mapping tool and to related water program information, including a list of impaired waters from the 303(d) list, water quality standards, and designated uses. The following sections provide instructions on using these sites to locate and document key characteristics of your watershed and print out a map. 3-2.1 Form 1—Identify the Watershed Name and Hydrological Unit Code (HUC) The first step is to fill in Form 1 about your municipality’s watershed and its 8-digit HUC using information provided by EPA, your state, and other resources. A HUC is a numbering system the U.S. Geological Survey (USGS) developed, which uniquely identifies all watersheds in the United States. The HUC, commonly called a "watershed address," ranges from 2 to 16 digits—the higher the number is, the smaller the watershed. Exhibit 3-1 shows examples of 2- to 12-digit HUCs. Exhibit 3-1. Sample Hydrological Unit Codes Description
Region Subregion Basin Subbasin Watershed Subwatershed

Locate your watershed
Locate your municipality and its watershed using the locator function on EPA’s Surf Your Watershed Internet site at http://
cfpub.epa.gov/surf/ locate/index.com, or

contact your state water permitting program.

A HUC is a watershed’s address
The watershed's HUC is commonly called its "watershed address." The U.S. Geological Survey provides access to watershed GIS boundary files on its Internet site at
http://water.usgs.gov/ GIS/huc.html.

Proper name
Ohio River Wabash and White Rivers Wabash River Vermilion River North Fork Vermilion Lake Vermilion

HUC
05 0512 051201 05120109 0512010909 051201090905

Digits
2 4 6 8 10 12

Watershed Impact Assessment Guidance for Public Lands and Facilities

3-3

Form 1. Summary of the Municipality’s Receiving Watersheds and Associated Waterbodies
Instructions: Complete this form for each 8-digit HUC watershed. Enter watershed priority scores (WPS) from Form 2. Please attach your watershed map to all Form 3s.

1. Name

2. State and County

3. Zip Code(s)

4. Name of 8-digit HUC watershed(s)

5. 8-digit HUC(s)

6. List of the Receiving Watersheds or Waterbodies Listed as Impaired by the Federal or State Regulators
Name of waterbody HUC, 8- to 16-digit, or state identifier List of impaired designated uses Summary of impairments of concern (from Form 2) WPS (from Form 2)

7. List of the Receiving Watersheds or Waterbodies Listed as Impaired by the Federal or State Regulators
Name of waterbody HUC, 8- to 16-digit, or state identifier List of designated uses Summary of impairments of concern (from Form 2) WPS (from Form 2)

3-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Identify Your Watershed and Assess Its Current Condition Complete Form 1 as follows: Blocks 1 through 3. Enter the municipality’s name, state, and zip code. Blocks 4 and 5. Go to EPA’s Surf Your Watershed site at http://cfpub.epa.gov/surf/locate/index.cfm as shown in Exhibit 3-2. Enter your municipality’s zip codes into the “Locate by geographic unit” box. This provides the “Watershed Profile” (at the 8-digit HUC) for your municipality. Enter the watershed name and 8-digit HUC into blocks 4 and 5. Exhibit 3-2. Example EPA Surf Your Watershed Locator

Enter Zip Code

You may also use the “search by map” function at the top of the screen to locate the watershed. If using the mapping function, select the state your municipality is in, and drill down to your general location until the “watershed profile” page is returned.

Watershed Impact Assessment Guidance for Public Lands and Facilities

3-5

Block 6. To obtain the 303(d) listed waterbodies, use one of the following sources: State Water Management Agency. Call your state water management agency or visit their website, which usually includes the latest 303(d) report. The 303(d) report lists the impaired waterbodies. If your waterbody is not listed, then it is not impaired. WATERS Website. Use the WATERS website at http://www.epa.gov/waters/enviromapper/index.htm. Select the area on which you would like information, such as by zip code, and enter the appropriate information. Then click on the “Zoom to Selected Area” button. A map of that area will appear. Select the “Update Map” button. A map of the impaired waterbodies in that area will appear. Select “identify active feature” and click on the “Update Map” button. Information on the impaired waterbodies appears below the map (Exhibit 3-3). You may need to use the zooming tools to identify the impaired waterbodies. TMDL Website. Use the TMDL website at http://www.epa.gov/owow/tmdl (Exhibit 3-4). Click on your state, then the waters listed by watersheds, and then your watershed. This will return a list of the 303(d)-listed waterbodies in the watershed. Click on your waterbody. For each listed waterbody, the website provides the following information: name, parameters (pollutants) of concern, priority for TMDL development, and potential sources of impairment. Copy the listed waterbodies, HUC, and parameters of concern to the appropriate column under block 6. The priority score, or WPS, you enter in column 4 under block 6, is determined in Form 2. Block 7. Identify and list the waterbodies not listed as impaired but that are still a priority for your municipality. For each waterbody listed in block 7, complete a separate Form 2. Form 2 enables you to develop a WPS for each waterbody. Block 8. Identify potential regional watershed partners by referring to http://www.epa.gov/win/contacts.html. List each potential partner in block 8. You will also be asked to use this information to complete the Regional Partnering Template located in Chapter 6.

Current 303(d) list List States are required
to update their list of impaired waters every 2 years. When identifying whether your municipality’s waterbodies are impaired, make sure you are using the latest 303(d) list

3-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Identify Your Watershed and Assess Its Current Condition

Exhibit 3-3. Example of EPA WATERS Map

Exhibit 3-4. Example EPA TMDL Website

Watershed Impact Assessment Guidance for Public Lands and Facilities

3-7

3-2.2 Form 2—Calculate WPS for Each Waterbody Listed on Form 1 Complete a separate Form 2 for each waterbody listed in Form 1. Use the information provided by EPA on its Surf Your Watershed site to assess the WPS. The WPS is the sum of the watershed indicator condition and vulnerability scores, plus points applied to the TMDL and compliance-based questions found in Form 2. Calculating a WPS enables you to prioritize the sensitivity of your waterbodies and thus the activities that occur in their drainage basin. The higher the WPS is, the more sensitive the watershed is to municipal activities. Use the following instructions to complete Form 2: Block 1. Enter the name and HUC for the waterbody listed in blocks 6 or 7 of Form 1. Block 2. For the waterbody listed in block 1, answer questions 2a through 2i, which determine the designated uses of the waterbody and whether it meets them. Go to the state regulator or EPA’s state 305b reports to determine the waterbody’s designated uses. The designated uses are from EPA’s national use support categories, Guidelines for Preparation of the Comprehensive State Water Quality Assessments (305(b) Reports) and Electronic Updates. Your state may have state-specific subcategories, which you can enter in block 2i. For each designated use, check the degree to which it meets the use, the impairments, and the causes or stressors of them. For example, if the waterbody does not fully support the water use classification of fishing and non-point source pollution from urban runoff is the cause of the impairment: check “partially supporting” for 2b and enter nonpoint source pollution as the impairment and urban runoff as the cause. If you do not know the answer for the specific waterbody, enter the default value for the corresponding 8-digit HUC. Block 3. List the state 303(d)-listed pollutants of concern (impairment) from block 2. Note whether or not the state has developed a TMDL for the waterbody. EPA and the states provide this information for most waterbodies on EPA’s TMDL tracking site at http://www.epa.gov/waters/tmdl/ and the 303(d) list. If the TMDL is in place, note the effective date.

3-8

Watershed Impact Assessment Guidance for Public Lands and Facilities

Identify Your Watershed and Assess Its Current Condition

Form 2. Watershed Priority Score (WPS): A Sensitivity Scoring and Data Collection Form for Waterbodies/Watersheds
Complete a Form 2 for each waterbody listed Form 1. Record the WPS and pollutants of concern into Form 1 for each waterbody. 1. Name of the Watershed and Corresponding 8- to 16-Digit HUC Code (or State Identifier): 2. Waterbody/Watershed Impairment Score for the watershed listed in Block 1. Go to the State regulator or EPA’s State 305b reports to determine the waterbody’s designated uses and if they are being met. For each designated use, check the degree it meets the use, the impairment(s), and the causes/stressors.
Not Supporting = 3 pts Partially Supporting = 2pts Fully Supporting = 1pt Not a Designated Use= 0 pts

Designated Use a. Aquatic life use b. Fish consumption use c. Shell fishing use d. Swimming use e. Secondary contact use f. Drinking water use g. Agriculture use h. Cultural/ceremonial use i. State/municipal specific use _______________________

Impairment

Cause/Stressor

3. Transfer the State 303(d) listed pollutants of concern (impairments) from question 2 and note if the State has developed TMDL. a. 303(d) Impairment 1: b. 303(d) Impairment 2: c. 303(d) Impairment 3: d. 303(d) Impairment 4: e. 303(d) Impairment 5: 4. Waterbody/Watershed Vulnerability Score for the watershed listed in Block 1.

TMDL in place?
Yes = 3 pt No = 0 pts

Enter TMDL Effective Date

Yes = 1 pt

No = 0 pts

a. Are the impervious surfaces above 25% of watershed land area (for either current or projected land use)? b. Is the population growth rate of the watershed above 7%? c. Does waterbody contain impounded water (e.g., dams and fish barriers)? d. Is the receiving water listed as a protected estuary? 5. Has EPA, individual service, state, water authority, or local group listed restoration goals for the waterbody in Block 1? If so, list the specific goals. a. Biodiversity and habitat loss. If yes, list goal: b. Riparian buffer strip loss. If yes, list goal: c. Imperviousness/uncontrolled SW runoff. If yes, list goal: d. Invasive species. If yes, list goal: e. Wetlands. If yes, list goal: f. Other: If yes, list goal: 6. Has an enforcement official requested the municipality to monitor/sample the waterbody? 7. Have water withdrawal/use restrictions been imposed for the waterbody? 8. Have potential impacts to human health been identified as a significant concern for the waterbody (e.g., air deposition of a pollutant to the waterbody, or pollutants in the water are causing a risk to drinking water)? 9. Is this watershed or waterbody designated as a special water resource under the American Heritage River Program, Great Lakes Program, Scenic Waters Program, or another special program?
Yes = 1 pt No = 0 pts

10. Watershed Priority Score (WPS) = impairment score (blocks 2 a-i) + TMDLs (blocks 3 a-e) + vulnerability score (block 4 a-d) + goal score (blocks 5 a-f) + answers on blocks 6 to 9.

Watershed Impact Assessment Guidance for Public Lands and Facilities

3-9

Block 4. For the waterbody listed in block 1, answer “yes” or “no” to questions 4a through 4d to determine the waterbody’s vulnerability. Question 4a. Is the percentage of impervious surfaces above 25 percent of the watershed land area for either current or projected land use? This information can be obtained by contacting your state water program point of contact or from EPA’s watershed indicators site at http://www.epa.gov/iwi/. Question 4b. Is the projected population growth rate of the watershed above 7 percent? This information can be obtained from your watershed’s profile page on EPA’s watershed indicators site at http://www.epa.gov/iwi/. Question 4c. Does the waterbody contain impounded waters such as dams or fish barriers? This information can be obtained from your watershed’s profile page on EPA’s watershed indicators site at http://www.epa.gov/iwi/. Question 4d. Is receiving water listed as a protected estuary? This information can be obtained from EPA’s National Estuary Program site at http:// www.epa.gov/ owow/estuaries/find.htm. Block 5. Has EPA, an individual service, state, water authority, or local group listed restoration goals for the watershed or waterbody? If so, list the specific waterbody or watershed restoration goals associated with each category. These goals can serve as potential watershed restoration performance metrics. Information about the active groups in the watershed can be obtained from your watershed’s profile page on EPA’s Surf Your Watershed site under the “Environmental Websites” heading. Block 6. Has a federal, state, or local enforcement official requested that the municipality monitor or sample the watershed or waterbody? Contact your state water program point of contact for environmental permits. Block 7. Have water withdrawal or use restrictions been imposed on this waterbody? Contact your state drinking water point of contact. Block 8. Have potential impacts to human health been identified as a significant concern for the waterbody? Contact your state drinking water point of contact.

3-10

Watershed Impact Assessment Guidance for Public Lands and Facilities

Identify Your Watershed and Assess Its Current Condition Block 9. Is this watershed or waterbody designated as a special water resource under the American Heritage River Program, Great Lakes Program, Scenic Waters Program, or other special program established to protect the water resource? Refer to EPA’s Surf Your Watershed site at http://cfpub.epa.gov/surf/locate/index.cfm for more information. Block 10. Calculate the total WPS for the waterbody by adding the overall watershed condition score (blocks 2 a-i), TMDL score (3 points for each yes in blocks 3 a-e), vulnerability score (1 point for each yes in blocks 4 a-d), watershed goal score (1 point for each yes in blocks 5 a-f), plus 1 point for each yes to answers on blocks 6 to 9. Remember to complete a separate Form 2 for each waterbody listed in blocks 6 and 7 of Form 1. After completing each Form 2, record the WPS on Form 1, blocks 6 and 7, as a summary sheet.

3-3 Create Watershed Map
To continue the assessment process, you need to create a map of the municipality in relation to the watershed and waterbodies. Creating a map that models hydrologic conditions and land use can identify watershed areas with the greatest potential impact on source water quality. Many state and municipal agencies have in-house GIS capabilities. Most maintain a GIS map of the municipality that contains various data layers that will be helpful in creating the watershed map. A GIS is an effective way to develop a map of the municipality. It presents selected data layers from the watershed assessment process into an easily interpreted format. You should create a municipal map that shows the following data layers: Watershed (e.g., 8 digit HUC) and subwatershed (e.g., 10-16 digit HUC) boundaries Municipal boundaries Topography All major NPDES discharge points Vegetative cover Waterbodies and points flowing on- and off-site Major structures, utility lines, and roads.

Aerial and topographic maps are available online
The following Internet sites contain various digital and topographic maps that can assist with watershed efforts: USGS provides digital, topographic, and HUC maps. WATERS is an Internet-based GIS mapping tool. Montana State University maintains an extensive online collection of HUC maps backed up with digital maps.

Watershed Impact Assessment Guidance for Public Lands and Facilities

3-11

You may need to create the watershed boundary layer. Delineating watersheds is generally a straightforward process, but it may not be the easiest step, depending on the type and number of subwatersheds involved in the municipality. The delineation involves identifying the drainage area above municipal boundaries on a topographic map. In some cases, the total watershed area may be very large, thus prohibiting the investigation of all contributions from pollutant sources over such a wide area. The watershed drainage area must still be defined in order to identify the total area contributing to the water quality in the watersheds affected by the municipality and to eventually consider all potential contributors to any identified impairment. As assessments are completed for other water systems upstream, that information will be available for review and incorporation into your assessment and protection plan. The USGS provides detailed guidance and hard-copy maps on delineating surface watersheds on their User's Guide for Source Water Assessment and Protection at http://water.usgs.gov/usaec/tools.html. A number of federal, state, and local government agencies may already have topographic data in digital form, including the delineation of various watersheds and aquifer boundaries. These sources should be contacted first to reduce duplicate effort. State or regional geologic agencies should be the first source for hydrogeologic conditions of the area, and will most likely have studied the conditions in great detail. State agencies also know the information available in digital or other format such as reports and studies. A listing of state agencies is available at http://www.epa.gov/OGWDW/source/contacts.html. In addition, digital and topographic maps of 8-digit HUCs are available from the following sources: Web-based watershed mapping tools
► ►

EPA’s WATERS site at http://www.epa.gov/waters/ The Montana State University website at http://www.esg.montana.edu/gl/huc/index.html.

Digital USGS topographic maps. The USGS identifies many places to get topographic maps and aerial photos. Access the USGS site at http://mapping.usgs.gov/. It also provides access to watershed GIS boundary files on its site at http://water.usgs.gov/GIS/huc.html.

3-12

Watershed Impact Assessment Guidance for Public Lands and Facilities

Identify Your Watershed and Assess Its Current Condition

3-4 Select Goals and Performance Metrics
Having systems in place to measure and communicate progress is a critical part of improving a watershed’s health and ensuring environmental burden is integrated into asset management. Therefore, this guide includes a block on Form 1 to identify measures of progress (often referred to as “performance metrics”) for a specific watershed. Appropriate measures not only keep watershed issues on management’s mind, but, as they are met, they allow stakeholders to share successes and highlight new challenges to the watershed. Make sure that the appropriate measures of progress are selected and that information on these measures is shared with relevant stakeholders. Measurements of progress should be associated with achieving goals set for the municipal watershed effort. Work with your municipality’s environmental office to develop specific watershed restoration goals. Then determine how they tie into asset management. For example, you may choose meeting water quality measurements (such as decreasing the percentage of dissolved oxygen, bacteria levels, or fecal coliform) or less direct water-quality based results (such as number of feet of wastewater collection pipes retrofitted, number of miles protected from erosion, or number of trees planted). To make sure that progress does indeed occur, the watershed restoration goals should be incorporated into the asset management plan. For many watersheds around the country, different stakeholders, including regulators, have identified specific restoration goals. For example, the Chesapeake Bay Program has set various goals to improve the Chesapeake Bay watershed. One such goal is to have ”a Chesapeake Bay free of toxics by reducing or eliminating the input of chemical contaminants from all controllable sources to levels that result in no toxic or bioaccumulative impact on living resources that inhabit the Bay or on human health.” The Puget Sound Water Quality Action Team has set a variety of goals, including reducing non-point source pollution and nuisance species. Most of these goals are voluntary, but the trend is for them to become mandatory. For example, the Estuaries and Clean Waters Act of 2000 requires federal agencies in the Chesapeake Bay Watershed to comply with previously voluntary Chesapeake Bay agreements. Thus, you should clarify your goals so that they focus the municipality’s actions on the impacts they have on the watershed, the resources they control, and the specific property within municipality boundaries.

Watershed Impact Assessment Guidance for Public Lands and Facilities

3-13

3-5 Conclusion
The previous sections provide instructions for completing Forms 1 and 2. At this point, you should have identified the watershed name and HUC number, created a map of the watershed and its boundaries, identified overall impairments, watershed conditions and potential

prioritized the condition and vulnerability of municipality’s watersheds, and identified key goals and performance metrics to guide the prioritization of projects and enable you to track progress over time. The next chapter provides you with instructions on how to identify and prioritize specific municipal land-use conditions and activities that may be contributing to the watershed impairments listed on Form 1.

3-14

Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter 4 Assess Potential Impact of Municipal Land Use and Activities
4-1 Introduction
The next step in the watershed assessment process is to identify the municipality’s physical characteristics (such as land uses, soil types, and structures) and associated activities. This chapter provides instructions for completing the following forms: Form 3, Summary List of Priority Municipal Activities (see Appendix C for a checklist of typical activities) Form 4, Summary of Municipal Land Use Categories Form 5, Summary of Questions to Identify Key Municipal Physical Characteristics and Activities Form 6, Parts 1–3, Municipal Activity Data Entry Sheet. You should find most, if not all, of the information to complete these forms in existing sources. When complete, these forms enable you to do the following: Validate a list of activities occurring across your municipality. Create a list of priority municipal activities that have the potential to contribute to specific watershed impairments of concern. Identify baseline land-use conditions that may be contributing to general watershed impairments. Create a relative TABS for each activity to assist in quantifying its potential impact relative to the condition of the watersheds identified in Form 1.

Summary
This chapter helps you complete Forms 3 through 6. In this chapter, you will identify specific land use; assess baseline land use conditions and industrial activities; create a list of priority municipal activities with the potential to contribute to watershed impairments; and create a relative total activity burden score (TABS) for each activity.

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-1

4-2 Form 3—Develop an Initial List of Activities
Appendix C provides an initial inventory of the activities that may significantly impact the watershed or that may be affecting the state’s TMDL process. The first step is to refer to the summary checklist of typical activities in Appendix C. Check each activity on the list that occurs at your municipality and enter its name and location onto Form 3. Enter the receiving waterbody in Question 4. You will develop a Form 6 for each activity listed in Form 3, transferring your answers from Form 6 to questions 5–8 once you have completed it.

4-3 Form 4—Develop a Summary of Municipal Land Use Categories
Watershed management involves gaining an understanding of the municipality’s land use and hydrological processes that govern the flow, quality, and velocity of water running onto and off the lands. Understanding this process requires, among other things, current data on the amount and type of land cover. Local watershed groups or regulators also use these measurements as targets for watershed restoration goals (for example, the percentage of stream miles containing adequate riparian buffer zones). To complete Form 4, which creates a snapshot of your municipality’s land-use averages, you may have to review the municipal master plan or land-use plan, GIS layers, zoning maps, and stormwater pollution prevention plans. Once you complete Form 4, compare the results with the surrounding watershed. Pay particular attention if the percentage of impervious areas on your municipality is greater than the average value in the watershed. This may indicate that you need to investigate additional storm water control mechanisms. Various studies have shown that as the amount of impervious areas increases in a watershed, its quality decreases. Therefore, municipalities should consider ways to mimic the site’s natural hydrology by further minimizing impervious areas, which reduces stormwater runoff to predevelopment. To complete Form 4, you should also refer to Form 3 to determine the total number of activities in each land-use category, determine the total acres for each land-use category, calculate pervious and impervious percentages, and obtain land-use goals, municipal sustainability goals, or watershed goals found in the land-use plan and expressed by EPA, the state, or public and private watershed groups.

4-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Assess Potential Impact of Municipal Land Use and Activities

Form 3. Summary List of Municipal Activities That Potentially Affect the Watershed
5. Compliance burden (e.g., governing laws, regulations, and required permits or plans) 4. Potential activity watershed impact a. Contributes the following regulated impairments (e.g., TMDLs) b. Contributes the following other impairments

6. Total Activity Burden Score (TABS=WPS+AIS)

1. Activity name

2. Activity location

3. Waterbody or subwatershed affected

Date Baseline Completed:

Page ___ of ____

Watershed Impact Assessment Guidance for Public Lands and Facilities

7. Pollution prevention or enhancements possible? (Yes or No)

Activity ID #

4-3

Form 4. Summary of Municipal Land Use Categories
Total # pervious acres Total # of Activities in each category (Refer to Form 3) Total acres in each category Land use improvement goal (%) Acres covered by SWP3 or other plan (specify) Total % impervious

Total # impervious acres

Total % pervious

Description of Land Use Categories Industrial: (Including: Facility Operations & Maintenance Areas, Motor Pools, Equipment & Material Storage Areas, Truck Parking, Wash Racks, Fueling Points, Industrial Treatment Plants, Fumigation Areas, or Shipping/Receiving Areas) Urban (Including: Commercial – Shopping Centers, Grocery Stores, Restaurants, Banks, Parking; Residential – Housing and Parking; Office Buildings and Parking; and roads) Mixed Use: (including gravel areas, low impact parking lots, total semimaintained open grounds (e.g., operational buffers and firebreaks), and recreational grounds (e.g., ball fields, horse stables, golf courses) Paved Roadways Construction Agricultural Operations Natural Areas Non-riparian forest Riparian forest and buffer strip Wetlands Grasslands or prairie Endangered species conservation areas Waterbodies (stream, pond, or other) Coastal area or estuary Other natural areas (e.g., beaches and deserts) Acres of natural areas slated as protected critical areas

Total for municipality:
Baseline conducted by: Date:

4-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

% of goal accomplished

Assess Potential Impact of Municipal Land Use and Activities

4-4 Form 5—Identify Key Physical Characteristics and Activities
Complete Form 5 using the list of municipal activities developed in Form 3. Form 5 contains a series of questions that help you identify only the activities that have the highest potential to impact water resources. Form 5 also provides the screening questions that help you complete Form 6. Before answering the questions in Form 5, obtain and review the following information: Municipal master plan or land-use plan containing size, location, land use, natural resources, and nature of current and planned activities Meteorological, soil, and topography data, including average rainfall, soil characteristics, types of ground cover, and topography Municipal environmental permits, plans, compliance status, and environmental management system (EMS). The questions on Form 5 are self-explanatory. Respond to each with “yes,” “no,” or “unsure.” If yes, note the estimated number of activities or the approximate area (such as number of acres) affected. If unsure, describe your reasons. You can also provide additional comments to clarify answers or describe the location of the activities of concern.

To complete Form 5, users should review the following:
1. Forms 3 and 4. 2. Meteorological, soil, and topography data. 3. Environmental permits, plans, and compliance status. 4. Environmental management system (EMS).

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-5

Form 5. Summary Questions to Identify Key Physical Characteristics and Activities That May Potentially Impact the Watershed
Typical impacts or concerns with activity
Aquatic habitat degradation, sedimentation, and flooding

Question about municipality characteristics or activities 1. Does the municipality contain streams or rivers that have visible signs of bank erosion, scouring, or unstable stream banks? If yes, note if caused by municipal or off-site activities. 2. Does the municipality contain streams or rivers that have barriers to fish spawning? If yes, note if caused by municipal or off-site activities. 3. Does the municipality contain areas that exhibit uncontrolled flooding during rain events? If yes, note if caused by municipal or off-site activities. 4. Does the municipality contain streams or rivers without adequate riparian buffer (as defined by watershed goals or local zoning requirements)? 5. Does the municipality contain steep slopes or other areas that exhibit visible signs of erosion? If yes, note if caused by municipal or off-site activities. 6. Does the municipality contain impervious areas (roads, parking lots, buildings, etc.) that drain directly to receiving waters without retention or detention controls? 7. Do any upstream properties or activities drain onto the municipality that may affect water quality or cause on site flooding or stream scouring? 8. Does the municipality contain septic systems or other underground injection wells?

Number of activities (on-site)

Unsure

Yes

No

Comments

Aquatic habitat degradation, sedimentation, and flooding Aquatic habitat degradation, sedimentation, and flooding Aquatic habitat degradation and sedimentation

Sedimentation and flooding

Flooding and aquatic habitat degradation Flooding, toxic or conventional pollutants, TMDLs, and aquatic habitat degradation Toxic or conventional pollutants to aquifers and TMDLs

Note: For each question answered yes or unsure, list a specific activity or area on Form 3. For each activity listed on Form 3, complete a Form 6.

4-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Assess Potential Impact of Municipal Land Use and Activities

Form 5. Summary Questions to Identify Key Physical Characteristics and Activities That May Potentially Impact the Watershed (Continued)
Typical impacts or concerns with activity
Regulatory burden such as source water protection, wellhead protection, or conservation plans Toxic or conventional pollutants, TMDLs, sedimentation, spills, and regulatory burden (e.g., plans) Spills to surface or ground waters and regulatory burden Toxic pollutants, TMDLs, spills, and regulatory burden Toxic or conventional pollutants, TMDLs, spills, and regulatory burden Toxic or conventional pollutants, TMDLs, spills, and regulatory burden Sedimentation and regulatory burden

Question about municipal characteristics or activities

Number of activities (on-site)

Unsure

Yes

No

Comments

9.

Does the municipality produce its own drinking water? If yes, note if using ground or surface waters

10. Does the municipality conduct industrial activities that require NPDES wastewater, pretreatment, or storm water discharge permit?

11. Does the municipality maintain bulk storage of POLs or EPRCA chemicals in USTs or ASTs? 12. Does the municipality conduct fleet fueling operations or operate fueling stations? 13. Does the municipality have uncovered bulk storage of industrial chemicals, materials, wastes, or equipment (e.g., salt or coal piles)? 14. Does the municipality apply fertilizers or pesticides on its property? 15. Is the municipality undertaking or planning major construction or ground disturbing activities?

Note: For each question answered yes or unsure, list a specific activity or area on Form 3. For each activity listed on Form 3, complete a Form 6.

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-7

4-5 Form 6—Municipal Activity Data Sheet
Form 6 allows you to record all the information needed to assess each activity’s impacts on the watershed identified in Form 3. It contains 6 parts to include: Part 1. Describe the activity, its potential impacts, and identify its receiving waterbody.

Electronic Version of Form 6
The electronic version of this protocol contains an electronic version of Form 6. The scores are automatically calculated using an MS Excel spreadsheet.

Part 2. Quantify the activity’s potential impact. Part 3. Assess potential pollution prevention (P2) opportunities. Part 4. Determine project objectives. Part 5. Select BMPs, estimate costs, and identify sources of funds. Part 6. Identify project lead and potential project partners. Complete a separate Form 6 for each activity validated in Form 3. This chapter provides detailed instructions for completing Parts 1, 2, and 3 of Form 6. Chapter 5 provides instructions for Parts 4 and 5 of Form 6. Chapter 6 provides instructions for Part 6 of Form 6. The electronic version of this protocol contains an electronic version of Form 6. The form automatically calculates the activity’s scores. Although most of the information required to complete Form 6 may already be available in existing reports, you may want to walk around the municipality to document current conditions at each of the activity sites, as well as to talk to personnel in charge of each activity. 4-5.1 Form 6, Part 1—Describe the Activity, Its Potential Impacts, and Identify the Watershed or Waterbody The following instructions will help you complete Part 1 of Form 6 (the instruction number corresponds to the block numbers on the form): 1. 2. Enter name of activity. This name should be clear and concise. Provide a detailed description of the activity and its operations. Note how often the site is used for the activity: continuous, daily, monthly, sporadically, etc. The amount helps you rate the activity’s impact. Enter the location of the activity. Refer to the watershed map quadrants or latitude and longitude, if applicable. List the office responsible for operating the activity.

3. 4.

4-8

Watershed Impact Assessment Guidance for Public Lands and Facilities

Assess Potential Impact of Municipal Land Use and Activities 5. Enter a tracking number unique to the activity: a tracking number you currently use, a Standard Industrial Classification (SIC) number, or other number. Describe current mitigation efforts or past restoration efforts in place at each activity. This can include a description of the type of equipment, the structural controls, or the management practices in place. Estimate the annual operation and maintenance (O&M) costs for mitigation efforts described in Block 6. If exact figures are not available, provide a rough estimate. Check all laws and regulations that regulate or permit the operation of the activity or its discharges. Refer to Appendix B, which contains a list of the environmental laws and regulations associated with typical municipal activities. List the specific environmental permits or plans required by law that the activity must have to operate. List the waterbody’s name and 8-, 10-, or 12-digit HUC from Form 1. Enter the WPS for that waterbody as determined on Form 2. List the TMDL pollutants or 303(d) listed pollutants of concern that may be released by the activity. For each pollutant, choose “yes” if the TMDL exists or is planned to be online within 2 years. This information is available from Form 2. For each pollutant, also note if its release is based on an estimate (such as professional judgment) or if it has been determined from sampling results. Check all of the activity’s other potential impacts (“K” for known or “P” for potential). Refer to Appendix C, which contains a list of common activities and the typical environmental impacts associated with each.
Form 6, Part 2—Quantify the Activity’s Impact and Determine the Total Activity Burden Score

6.

7.

8.

9. 10. 11. 12.

13.

4-5.2

The AIS enables you to develop a quantitative baseline of current activities that may contribute to waterbody impairments. This information is particularly useful for municipalities in areas where the state is developing TMDLs. In addition, the process also supports users who are attempting to develop an EMS by creating a prioritized list of municipal activities that have an environmental aspect and impact. The scoring approach is based on EPA, DoD, and Department of Energy (DOE) risk ranking systems. The user develops the activity Watershed Impact Assessment Guidance for Public Lands and Facilities 4-9

impact “score” by considering the severity of the impact and its frequency. In general, users first, estimate the likelihood that a specific impact will occur (such as 1 chance in 100 events) or the frequency of an activity (such as number of car washes conducted in a year). Exhibit 4-1 contains four categories of likelihood or frequency (LF) and assigns a LF value (LF0, LF1, LF2, or LF3). Then, users estimate the severity (negligible to significant) of the impact if the event occurred using the severity (S) matrixes for each media (Exhibits 4-2 through 4-6) and select a corresponding S value (S0, S1, S2, or S3). Then using the selected LF value and S value, users can assign an activity impact score as shown in Exhibit 4-7. Mark the corresponding box for each applicable question on Part 2 of Form 6. Users should rely on existing studies or professional judgment when selecting a score in Part 2 of Form 6. The following instructions provide the detailed steps for scoring the municipal activity’s impact to surface water, groundwater, air quality, critical habitat, cultural resources, health and safety, and compliance burden. Exhibit 4-1. Definitions of Likelihood of Occurrence or Frequency of Event Categories
LF0 Negligible likelihood (such as one chance in a million events) of release or impact occurring, no known plan exists to conduct the activity, or the activity occurs less than once a decade Improbable likelihood or low frequency (such as 1 chance in 100) of release or impact occurring, or the activity takes place less than once a year Probable likelihood or low frequency (such as 1 chance in 10 events) of release or impact Very likely or high frequency (at least 1 chance every 2 events or continuous) release or impact, such as a constant discharge

LF1

LF2 LF3

14.

Surface water impact. For each activity, estimate the likelihood of impact occurring using Exhibit 4-1 and estimate the severity of the consequence using Exhibit 4-2 to select the appropriate AIS using Exhibit 4-7 for questions 14a–j. Then enter the corresponding answer on Form 6: a. Does the activity result in a direct point source discharge to surface water that is regulated under the CWA (do not include a discharge from storm water runoff)? b. Is the activity out of compliance with CWA regulations because it does not have an individual permit or is NOT included on the municipality’s permit? c. If the activity is permitted, is it currently out of compliance with the permit standards? d. Has the activity had past recurring non-compliance with permit standards and/or conditions?

4-10

Watershed Impact Assessment Guidance for Public Lands and Facilities

Assess Potential Impact of Municipal Land Use and Activities e. Does the activity have a discharge of storm water runoff from a “regulated” point source? f. Does the activity have storm water runoff from non-point sources?

g. Are the pollutants discharged from this activity to surface water the same as those pollutants listed on the state/EPA 303(d) list (TMDL) for this waterbody? h. Does the activity drain to a waterbody that is a source of drinking water? i. j. Is the activity located in a State-identified Source Water Protection Zone? Does the activity adversely affect flow of a waterbody through restrictions on water withdrawal or discharge volumes?

Exhibit 4-2. Definitions of Severity Categories for Potential Impacts to Surface Water Quality
S0 S1 The activity has no impact on surface water Minimal impact. The activity results in a discharge of pollutant or other impairment that has minimal negative impact on surface waterbodies: it is temporary, contained immediately around activity, and does not result in a release of a 303(d) listed impairment to waters of the state Moderate impact. The activity causes discharge of pollutant or other impairment that has moderate impact on surface water, and the pollutant(s) of concern or impairment(s) is listed as a 303d pollutant or cause of waterbody impairment, and the impact is local in scale; or not listed as a 303d pollutant or cause of waterbody impairment, and the impact is temporary and contained within the activity boundaries; or not listed as a 303d pollutant or cause of waterbody impairment, and the impact is temporary and contained immediately around the activity, but the waterbody is a source for potable water S3 Significant impact. The activity discharges a pollutant(s) or causes another impairment(s) that has a significant impact on surface water, including a discharge of a 303d or State listed impairment or causes an a 303d or state listed impairment that is persistent or an off-site impact; or the impact prevents a waterbody from meeting its intended uses

S2

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-11

15.

Groundwater impact. Use Exhibit 4-3 in conjunction with Exhibit 4-1 to select the appropriate color in Exhibit 4-7 for questions 15a–d. Then enter the corresponding answer on Form 6. a. Does the activity inject or have infiltration of a pollutant to groundwater? b. Does the activity discharge pollutants that violate drinking water maximum contaminant limits (MCLs) or water discharge permit limits to groundwater (if permitted)? c. Does the activity drain to groundwater that is a source of drinking water (aquifer or well)? d. Is the activity within 300 feet of a drinking water well or within a wellhead protection zone?

Exhibit 4-3. Definitions of Severity Categories for Potential Impacts to Groundwater Quality
S0 S1 Activity reduces amount of parameter released to groundwater Minimal impact. The activity causes discharge of pollutant or negatively impacts flooding or water supply, but the discharge amount or negative impact is minimal Moderate impact. The activity causes discharge of pollutant or negatively impacts flooding or water supply, but the discharge or negative impact is on post, temporary in nature and parameter, and not listed as a 303d pollutant or cause of waterbody impairment Significant impact. The activity causes discharge of pollutant or negatively impacts flooding or water supply, but the discharge or negative impact is listed as a 303d pollutant, the aquifer is source water, the scale of damage is off-post, or the impact prevents the waterbody from meeting its intended purposes

S2

S3

16.

Air quality impact. Use Exhibit 4–4 in conjunction with Exhibit 4-1 to select the appropriate color in Exhibit 4-7 for questions 16a–b. Then enter the corresponding answer on Form 6: a. Does the activity have non-permitted discharges to air that are also TMDL regulated pollutants? b. Does the activity have a permitted discharge to air that is also considered a TMDL regulated pollutant? If so, is this air discharge in compliance with the CAA permit?

4-12

Watershed Impact Assessment Guidance for Public Lands and Facilities

Assess Potential Impact of Municipal Land Use and Activities

Exhibit 4-4. Definitions of Severity Categories for Potential Impacts to Air Quality
S0 S1 The activity reduces amount of parameter released to air Minimal impact. The activity causes discharge of pollutant or negatively impacts air quality, but the discharge amount or negative impact is minimal Moderate impact. The activity causes discharge of pollutant or negatively impacts air quality, but the discharge does not migrate offpost and complies with air standards Significant impact. The activity causes discharge of pollutant that negatively impacts air quality, the discharge migrates off-post, and the discharge is beyond guidelines set by air standards

S2

S3

Use Exhibit 4-5 in conjunction with Exhibit 4-1 to select the appropriate color in Exhibit 4-7 for questions 17–19. Then enter the corresponding answer on Form 6. 17. 18. 19. Critical habitat impact. Does the activity disturb sensitive/critical habitat or endangered species habitat? Cultural resources impact. Does the activity adversely affect cultural resources or historic property? Health and safety impact. Does the activity discharge pollutant(s) that pose a risk to worker/public health and/or safety?

Exhibit 4-5. Definitions of Severity Categories for Potential Impacts to Questions 17–19
S0 S1 S2 S3 The activity positively impacts the ecosystem, cultural resources, or health and safety parameters Minimal impact. The activity causes minimal negative impact Moderate impact. The activity causes moderate negative impact, but only on post Significant impact. The activity causes significant negative impact, regional in scale, or affects sensitive areas or endangered species on post, or the impact is on off-post habitats

20.

Municipal compliance burden impact. Use Exhibit 4-6 in conjunction with Exhibit 4-1 to select the appropriate color in Exhibit 4-7 for question 20a–c. Then enter the corresponding answer on Form 6. a. Will a new operation cause the activity to have a new pollutant discharge to water resources that will increase compliance requirements or liability?

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-13

b. Does the activity require an environmental plan that calls for management of discharges to water resources? If yes, has the plan been implemented? If so, has the plan been unsuccessful in reducing discharges of pollutants to water resources? c. Is the activity currently out of compliance with other environmental laws or regulations (e.g., RCRA, FIFRA, CERCLA), or has it had recurring non-compliance for any discharge, spill, or injection of a pollutant to water resources? Exhibit 4-6. Definitions of Severity Categories for Potential Impacts to Municipal Compliance Burden
S0 S1 S2 No impact. The activity has no compliance requirement and requires no permit or plan Minimal impact. The activity is governed by environmental regulations, but has no regulatory requirement for a permit or plan to operate Moderate impact. The activity is governed by environmental regulations but has no regulatory requirement for a permit to operate, only a plan Significant impact. The activity is governed by environmental regulations and has a regulatory requirement for a permit and a plan to operate

S3

Exhibit 4-7. Definitions of Impact Scores in Form 6
Combined “S” and “L” response Yes or known significant impact (S3+L3 or S3+L2 or S2+L3) High probability or uncertain impact (S1+L3 or S2+L2 or S3+L1) Low probability but uncertain impact (S3+L0, S2+L1 or S1+L1 or S1+L2) No known or negligible impact (L0 or S0 in any combination) Answer for Form 6 3 points (red) 2 points (pink) 1 point (yellow) 0 points (green

21. 22. 23.

Identify other activity regulatory concerns or issues and rate the impact. Calculate the AIS by adding your answers to questions 14–21. Record the total in this block. The TABS equals the sum of the WPS you recorded in Block 13 of Form 2 and the AIS. This approach is based on the hypothesis that an activity’s total burden increases as the vulnerability of the ecosystem in which it operates increases.

4-14

Watershed Impact Assessment Guidance for Public Lands and Facilities

Assess Potential Impact of Municipal Land Use and Activities Once you have calculated an activity’s AIS and TABS, transfer these scores back into Form 1 to create a summary sheet of all activities and scores.
4-5.3 Form 6, Part 3: Assess Potential for Pollution Prevention Opportunities

This part of Form 6 allows you to identify activities that are candidates for elimination, outsourcing, consolidation, process reengineering, material substitution, or other P2 approaches. Candidate activities are ones that exhibit a relatively higher burden-to-municipal-need ratio. In other words, they cause a high environmental burden, but have a low municipal need. These are the activities that you should review for opportunities to reduce their impact by eliminating the activity, consolidating multiple activities, reengineering the activity, or implementing other pollution prevention approaches. 24. Determine the Municipal Need Score (MNS) by selecting the appropriate score: Score of 1. The activity is unrelated to the municipal functions or municipal operations would not be adversely impacted at all if the activity ceased operations. Score of 5. The activity is somewhat related to the municipal functions or municipal operations would be slightly adversely impacted if the activity ceased operations. Score of 10. The activity is critical to the municipal functions or municipal operations. 25. To determine the burden-to-municipal-need ratio, divide the TABS from Block 25 by the MNS from Block 23. 26. Check all the P2 options that may be appropriate for mitigating the impacts or compliance burden of the activity. Refer to Block 20 when making your selections. The following chapters of this guide provide instructions on how to complete the remainder of Form 6.

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-15

Form 6. Municipal Activity Data Entry Sheet - Part 1
Part 1. Describe the Activity, its Potential Impacts, and Identify its Watershed or Waterbody
1. Name of activity: 2. Describe activity:

3. Location(s):

4. Responsible office:

5. Unique activity ID# or SIC#:

6. Describe current mitigation efforts and past restoration efforts (Existing or Planned):

7. Estimate annual cost of mitigation efforts:

8. Check the laws that regulate/permit the operation of the activity: □CWA □RCRA □CAA □SDWA □EPCRA □ NCA □NHPA

□TSCA □FIFRA □ESA □CZMA □ NEPA □ State:_________________________ □ Local:_________________________ □ Other:_________________________
10. Receiving waterbody name and 10 –12 level HUC #, Form 1: Pollutant of Concern 12. List the TMDL regulated pollutants or 303(d) listed pollutants of concern released by activity from Form 2 303(d) Impairment 1: 303(d) Impairment 2: 303(d) Impairment 3: 303(d) Impairment 4: 303(d) Impairment 5: 303(d) Impairment 6:
K/P Release nutrient Release BOD/COD Release inorganic Release metals Release POLs Uncontrolled storm water runoff Release pesticides K/P Release TSS Cause erosion Cause thermal pollution Release pathogens Disrupt potable supply Release explosives Potential spill Release VOC/SVOC K/P
th th

9. List required permits and plans: a. _______________________________ b. _______________________________ c. _______________________________ d. _______________________________

11. WPS from Form 2: TMDL? yes yes yes yes yes yes no no no no no no
K/P Release SOx to air Release NOx to air Hazardous air pollutants Greenhouse gas emission Release PM 10 to air Violate noise standards Decrease riparian buffer Introduce invasive species Decrease wetlands Decrease fish spawning range Cause in-stream scouring Cause flooding

Sampled

Estimated

13. Check activity’s other known or potential pollutant releases or impairments (Check K for Known or P for Potential and check all that apply.)

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-16

Assess Potential Impact of Municipal Land Use and Activities

Form 6. Municipal Activity Data Entry Sheet (Continued) - Part 2
Part 2. Quantify the Activity’s Impact and Determine the Total Activity Burden Score
High probability or uncertain impact =2 pts No or negligible impact = 0 pt Low probability but uncertain impact =1 pt Yes or known significant impact = 3 pts

Answer the following questions to develop the activity's impact score (AIS):
(Use your own professional judgment, technical studies, monitoring data, and the instructions to answer the questions.)

a. Does the activity result in a direct point source discharge to surface waters that is regulated under the CWA (do not include a discharge from storm water runoff in this question)? b. Is the activity out of compliance with CWA regulations because it does not have an individual permit or is NOT included on the municipal permit? c. If the activity is permitted, is it currently out of compliance with the permit standards? d. Has the activity had past recurring non-compliance with permit standards and/or conditions?

14. Surface Water Impact

e. Does the activity have a discharge of storm water runoff from a “regulated” point source? f. Does the activity have storm water runoff from non-point sources? g. Are the pollutants discharged from this activity to a surface water the same as those pollutants listed on the state/EPA 303d list (TMDL) for this waterbody? h. Does the activity drain to a waterbody that is a source of drinking water? i. Is the activity located in a state identified Source Water Protection Zone? j. Does the activity adversely affect flow of a waterbody with restrictions on water withdrawal or discharge volumes? a. Does the activity inject or have infiltration of a pollutant to groundwater? b. Does the activity discharge pollutants that violate drinking water maximum contaminant limits (MCLs) or water discharge permit limits to groundwater (if permitted)? c. Does the activity drain to groundwater that is a source of drinking water (aquifer or well)? d. Is the activity within 300 feet of a drinking water well or within a wellhead protection zone? a. Does the activity have non-permitted discharges to air that are also TMDL regulated pollutants?

15. Groundwater Impact

16. Air Quality Impact

b. Does the activity have a permitted discharge to air that is also considered a TMDL regulated pollutant? If so, is this air discharge in compliance with the CAA permit? Does the activity disturb sensitive/critical habitat or endangered species habitat? Does the activity adversely affect cultural resources or historic property? Does the activity discharge pollutant(s) that pose a risk to worker/public health and/or safety? a. Will a new municipal operation cause the activity to have a new pollutant discharge to water resources that will increase compliance requirements or liability?

17. Critical Habitat Impact 18. Cultural Resource Impact 19. Health and Safety Impact

20. Compliance Burden Impact

b. Does the activity require an environmental plan that requires management of discharges to water resources? If yes, has the plan been implemented? If so, has the plan been unsuccessful in reducing discharges of pollutants to water resources? c. Is the activity currently out of compliance with other environmental laws or regulations (e.g., RCRA, FIFRA, CERCLA) or has it had recurring non-compliance for any discharge, spill, or injection of a pollutant to water resources?

21. Identify other activity regulatory concerns or issues and rate the impact.

a. b.

22. AIS Sum scores from questions 14 to 21 23. Total Activity Burden Score (TABS) = AIS+WPS (from Form 2):

Watershed Impact Assessment Guidance for Public Lands and Facilities

4-17

Form 6. Municipal Activity Data Entry Sheet (Continued) - Parts 3–6
Part 3. Assess Potential for Pollution Prevention Opportunities
24. Activity’s Municipal Need Score. Select either 1 (the activity is unrelated to the municipality or municipal operations would not be adversely impacted at all if the activity ceased operations), 5 (the activity is somewhat related to the municipal or municipal operations would be slightly adversely impacted if the activity ceased operations), or 10 (the activity is critical to the municipal operations) 25. Calculate the activity’s current Burden to Municipal Need Ratio which equals the TABS from Block 23 / MNS from Block 24. [Higher ratios identify high burdens, but activities with lower importance. These activities are excellent candidates for the P2 evaluations listed in Block 26]. 26. Check the following P2 options that are appropriate for mitigating the impacts or compliance burden of the activity: eliminate activity consolidate activity outsource activity implement process change change materials 10 5 1

Part 4. Determine Project Objectives
27. Are enhanced mitigation efforts needed for this activity? Specifically, do you want to: a. Reduce the amount of pollutants entering receiving waters? b. Reduce runoff velocities or mimic predevelopment runoff flow volumes? c. Improve reliability and ease of maintenance of existing BMPs? d. Comply with permit requirements (for pollutant removal or flow control)? e. Reduce lifecycle costs of existing operations or BMPs? f. Restore natural habitat g. Other (describe)_____________________________________________________ yes yes yes yes yes yes yes yes no no no no no no no no

Part 5. Select Project BMP, Estimate Costs, and Source of Funds
28. Describe selected mitigation project or BMP: If yes to #27, provide title of proposed BMP or control technology: 29. Cost Data Estimated total startup costs a. Estimated planning, design & permitting costs b. Estimated purchase/construction costs Estimated O&M costs $

30. Estimate a reduction in TABS, assuming successful implementation of the enhanced mitigation effort uses the same scoring sheet as your original TABS (Part 2). Enter new TABS here. 31. Calculate cost effectiveness of proposed project = revised TABS score / total start costs 32. Provide reference to detailed project sheet 33. List most appropriate source of funds (e.g., O&M): 34. Is project eligible for other funds (e.g., state grants, EPA grants, grants from other organizations, etc.):

Part 6. Identify Project Lead and Potential Project Partners
35. Project lead office: 37. Point of contact name: 39. List potential partners Organization name: Point of contact: Contact phone: Role in project: 36. Contact phone: 38. Contact e-mail:

40. Attach a picture of the location, impairment, or activity
Form created by: Date form created: Form revised by: Date form revised:

4-18

Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter 5 Select Mitigation Projects for High Priority Activities
5-1 Introduction
Once users have created an inventory of activities occurring on a property, described the current mitigation efforts in place (Forms 3 and 6), and identified whether there is an opportunity to apply P2 solutions (Form 6, Part 3), the next step is to determine whether enhanced mitigation efforts are necessary and, if so, identify the best solution to achieve the site objectives. This chapter provides instructions on how to complete Parts 4 and 5 of Form 6 by assessing the feasibility of implementing enhanced mitigation projects, such as structural or nonstructural BMPs; selecting the performance objectives for the potential BMP; selecting the most appropriate BMP; identifying performance, design, construction, maintenance, and cost factors for the selected BMP; and developing cost estimates. This chapter also lends additional assistance in identifying and selecting BMPs for typical activities. Appendix D contains an expanded list of available BMP guidance.

5-2 Identifying Best Mitigation Efforts or Best Management Practices
Identifying the best BMP or group of BMPs for an activity or site can be difficult, especially in the project’s conceptual phase. In general, a BMP should be chosen on the basis of its ability to cost-effectively achieve site-specific objectives.

Watershed Impact Assessment Guidance for Public Lands and Facilities

5-1

The following factors should be considered when selecting appropriate BMPs: Watershed Terrain Stormwater treatment suitability Physical feasibility Community and environment Location and permitting.1 More detail on a step-by-step screening process is provided below. 5-2.1 Form 6, Part 4—Determine Project Objectives This part of Form 6 helps you determine whether enhanced mitigation efforts are needed at the activity. From your answers, you can also determine the BMP objectives. The following instructions help you complete Part 4 of Form 6 for each priority activity. In answering the questions in Part 4, you should review your answers to Parts 1 and 2. Question 27a. Does the municipality want to reduce the amount of pollutants entering receiving waters? At a minimum, if you noted in Blocks 14, 15, 16, or 19 of Form 7 that the activity discharges a pollutant of concern, answer “yes.” Question 27b. Does the municipality want to reduce runoff velocities or mimic predevelopment runoff flow volumes? At a minimum, if you answered “yes” in Block 14, or checked “cause erosion” or “uncontrolled storm water runoff” in Block 13 of Form 7, answer “yes.” Question 27c. Does the municipality want to improve reliability and ease of maintenance of existing BMPs? To answer this question, you should confer with the maintenance staff. Question 27d. Does the municipality want to achieve permit requirements (for pollutant removal or flow control)? At a minimum, if the activity has a NPDES permit, answer “yes.”

1 This approach is based on the Center for Watershed Protection and Maryland Department of the Environment Water Management Administration Maryland Department of Environment’s 2000 Maryland Stormwater Design Manual Volumes I and II available at http://www.mde.state.md.us/environment/wma/stormwatermanual/ Manual_CD/Introduction.pdf.

5-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Select Mitigation Projects for High Priority Activities Question 27e. Does the municipality want to reduce life cycle costs of existing operations or BMPs? To answer this question, you should confer with the activities maintenance staff for suggested improvements. Question 27f. Does the municipality want to restore natural habitat? To answer this question, determine whether the activity affects natural habitat and whether an opportunity exists to restore the natural habitat on or surrounding it. Question 27g. Does the municipality have other objectives? Describe any other objectives not addressed above. Other factors that influence project objectives include the following: State, local, or other special considerations. Is the project located in a part of the municipality or watershed that has special design objectives or constraints that must be met? Table 4-1 of the Maryland Stormwater Design Manual, outlines BMP restrictions or additional design requirements that should be considered if a project lies within a critical area, a coldwater watershed, a sensitive watershed, an aquifer protection area, a water supply reservoir, or a shellfish or beach protection zone. (Your state may have specific requirements that must be met; check your state’s regulations.) Terrain. Is the project located in a portion of the state that has particular design constraints imposed by local terrain or underlying geology? The Maryland Stormwater Design Manual details BMP restrictions for regions that have karst, mountainous terrain, or low relief. Stormwater treatment suitability. Can the BMP meet stormwater sizing criteria at the site, or is a combination of BMPs needed? The solution should meet sizing criteria. Designers can screen the BMP list using local sizing criteria for volume and flow to determine whether the solution will work. Physical feasibility. Do any physical constraints at the project site restrict or preclude the use of a particular BMP? In this step, designers can determine whether the soils, water table, drainage area, slope, or head conditions present at a particular development site might limit the use of a BMP.

Watershed Impact Assessment Guidance for Public Lands and Facilities

5-3

Community and environment. Do the remaining BMPs have any important community or environmental benefits or drawbacks that might influence the selection process? The Maryland Stormwater Design Manual contains a checklist to compare BMP options in regard to maintenance, habitat, community acceptance, cost, and other environmental factors. Location and permitting. What environmental features must be avoided or considered when locating the BMP system at a site to fully comply with local, state, and federal regulations? In this step, designers can use Table 4.6 of the Maryland Stormwater Design Manual, as a checklist that asks whether any of the following are present at the site: wetlands, waters of the United States, stream or shoreline buffers, floodplains, forest conservation areas, and development infrastructure. The manual provides guidance on how to locate BMPs to avoid impacts to sensitive resources. 5-2.2 Factors in Developing Project Objectives When developing objectives, you should be fully aware of the situation for which the BMP is being considered. Municipalities start the BMP selection process for different reasons, including the following: New construction or activity. BMPs are selected to control the estimated runoff rates or pollutant loadings as part of a site development plan for new construction or a new activity. In these situations, municipalities usually have longer planning horizons and more influence in layout and BMP selection. However, most states provide minimum design and regulatory standards for BMPs proposed as part of new construction. Retrofitting existing activities or developed areas. BMPs are selected to control known (sampled) runoff flow rates or pollutant loadings as a retrofit to an existing single industrial activity. Municipalities usually have shorter planning horizons due to the compliance agreements and less latitude in selecting BMPs due to space and operational constraints. All states provide regulatory criteria for controlling point source discharges from existing industrial activities. In addition to regulating point source discharges, some states provide regulatory criteria for controlling runoff flows.

5-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Select Mitigation Projects for High Priority Activities BMPs are selected to control known (sampled) runoff flow rates or pollutant loadings as a retrofit to an existing multiple-use developed site (such as one containing both industrial activities and typical urban land uses). Municipalities usually have medium planning horizons due to the complex nature of the solutions and more latitude in selecting BMPs or groups of BMPs. Restoring water bodies or watersheds to achieve designated uses. BMPs are selected to achieve a waterbody’s or watershed’s designated use, such as lowering the temperature of a discharge to allow the receiving water body to meet temperatures necessary for fish survival. Restoring natural habitat. BMPs are selected to modify habitat (such as in streams, wetlands, or riparian buffers) to restore natural predevelopment conditions or mitigate the impacts on current development conditions. Municipalities should only implement these types of BMPs after upstream flows and pollutant loadings are controlled. Changing or creating operating and maintenance procedures for existing assets. For example, a municipality may switch from applying road salt to sand during winter weather conditions. Refer to Parts 1 and 2 of Form 6 to review the impacts caused by a specific activity.

5-3 Selecting Best Solution
Using the strategic asset management approach, BMP solutions are evaluated on the basis of their return on investment and whether they are achievable with municipal resources. Municipalities determine each solution’s return on investment by calculating the change in asset valuation—the difference between asset values based on the current environmental burden (TABS score) and future environmental burden—per unit cost. Municipalities then rank potential improvements on the basis of their return on investment and municipal budgetary constraints. Strategic asset management and asset valuation techniques are still in their infancy. Therefore, the Municipal Watershed Impact Assessment Process only provides environmental burden improvement and project costs rather than change in asset valuation. We suggest that municipalities use the environmental burden improvement and project costs as inputs to their strategic asset management systems to evaluate and rank projects on the basis of return on investment and total cost.

Watershed Impact Assessment Guidance for Public Lands and Facilities

5-5

Use the following steps in filling out Form 6, Part 5, to select the BMPs, determine costs, and determine sources of funds: Review Exhibit 5-1, which summarizes innovative BMPs that are low cost, low impact, low maintenance, and effective in reducing pollutants in water bodies. Consider the site’s physical characteristics (refer to Form 5) when selecting a BMP. From your assessment, select mitigation efforts that provide the most cost-effective impact reduction. Enter the name and a description of the proposed mitigation effort in Block 28. Describe the proposed BMP or control technology that can better mitigate the activity’s impact. For each mitigation project considered, calculate its planning, design, and permitting costs, and enter the amount in Block 29a. Estimate purchase price or construction costs, and enter the amount in Block 29b. Estimate annual O&M costs, and enter the amount in Block 29. (Appendix E contains references for costing BMPs.) Rescore the activity’s baseline score using the same scoring approach used in Part 2 of Form 6. Estimate your answers as if the proposed BMP was in place. Enter the new TABS in Block 30. Calculate the cost-effectiveness of the project by dividing the revised TABS score (Block 30) by the total start costs (Block 29). Enter the cost-effectiveness in Block 31. We suggest that municipal managers use the TABS scores for the pre-BMP condition (Block 23) and post-BMP condition (Block 30) and total costs (Block 29) as inputs to their strategic asset management system to evaluate projects. The project return on investment may be determined using the TABS scores to calculate the change in asset valuation and the project costs to provide expense cash flows. If the municipality does not have a strategic asset management system, the cost-effectiveness in Block 31 may be used to rank potential projects. In Block 32, note the project sheet number that contains the detailed project description. Since Exhibit 5-1 contains just a summary description, you need to prepare a detailed project summary sheet or project description. (Appendix G contains a sample project summary write-up sheet.) In Block 33, enter the appropriate source of funds. In Block 34, enter whether the project is eligible for other funding sources, such as state revolving loans or grants.

5-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Select Mitigation Projects for High Priority Activities

5-4 What to Do if Multiple Mitigation Efforts Are Possible
If multiple mitigation efforts are possible for a particular activity, select the alternative that provides the greatest reduction in TABS per dollar spent. Exhibit 5-1. Typical BMPs and Mitigation Efforts for High Priority Activities
Typical activity
Buildings

Typical mitigation activities
Use low impact development technologies Use proper erosion and sediment controls during construction operations Install sand filters Redirect roof runoff

References for additional BMP data
Whole Building Design Guide for environmentally sound site layout at http://www.wbdg.org/index.asp EPA’s Watershed Academy Module on Land Development at http://www.epa.gov/watertrain/ management The Stormwater Manager’s Resource Center at http://www.stormwatercenter.net/ Low Impact Development Center at http://lowimpactdevelopment.org/ links.htm - bmp_gen

Construction and other grounddisturbing activities

Control erosion—stabilizing exposed soils prevents storm water run-on and runoff (use geotextile materials where appropriate to prevent erosion) Use dry detention basins Cover excavated soils Remove contaminated soils and dispose of properly

NRCS Planning and Design Manual for the Control of Erosion, Sediment, and Stormwater at http://abe.msstate.edu/csd/pdm/index.html

Dams, culverts, or dredging

Regularly check effectiveness of dams and culverts Ensure proper placement of fill activities for dredging

The Stormwater Manager’s Resource Center at http://www.stormwatercenter.net/ DoD Joint Services P2 Library at http://p2library.nfesc.navy.mil/ Fact_Sheets/DSDATA/sortbysection. html#10 NASA water pollution control at http://www.wff.nasa.gov/~code205/ Services/Water Pollution/water_ pollution_control.htm New Hampshire Department for Environmental Services at http://www.des.state.nh.us/wmb.htm

Deicing material application

Reduce use or replace with environmentally friendly materials Collect and reuse materials (such as in aircraft deicing)

Watershed Impact Assessment Guidance for Public Lands and Facilities

5-7

Exhibit 5-1. Typical BMPs and Mitigation Efforts for High Priority Activities (Continued)
Typical activity
Drainage wells and canals

Typical mitigation activities
Construct vegetative strip and filters to catch sediment before it reaches the infiltration device Perform required maintenance and cleaning, primarily to prevent clogging

References for additional BMP data
EPA’s general BMPs at http://www.epa.gov/seahome/inject/src/ gbest.htm

Fixed-wing and rotary-wing aircraft maintenance activities

Use separate containers for disposal of wastes Recycle scrap metal Dispose of degreasing and other solvent materials properly Store containers on an impervious surface and properly cover against weather Provide equipment training

NASA Water Pollution Control at http://www.wff.nasa.gov/~code205/ Services/Water Pollution/water_ pollution_control.htm Aerospace Industry Notebook at http://www.epa.gov/compliance/ resources/publications/assistance/ sectors/notebooks/aerospace.html DoD Joint Services P2 Library at http://p2library.nfesc.navy.mil/index.htm EPA BMP Database at http://www.bmpdatabase.org/ The Stormwater Manager’s Resource Center at http://www.stormwatercenter.net/ Maryland Stormwater Management Program at http://www.mde.state.md.us/ environment/wma/stormwatermanual/ EPA’s general BMPs at http://www.epa.gov/seahome/inject/ src/gbest.htm

Fueling stations and operations

Connect drains from vehicle washing areas to the municipal sewer or sanitary sewer system Provide temporary protection of storm drains (temporary placement of absorbent material, storm drain covers, or shutoff valves) Equip fueling equipment with automatic shutoff nozzles Discourage topping off and unattended fueling Install oil-water separators or sand filters

Motor pools and vehicle maintenance centers

Park tank trucks or delivery vehicles away from unprotected storm drains and manholes or provide temporary protection Install sand filters, oil-water separators, or other BMPs that treat the runoff Perform maintenance inside or in an outside area where spills cannot enter storm drains

EPA Solutions to Pollution at http://www.epa.nsw.gov.au/ small_business/autoservicing.htm DoD Joint Services P2 Library at http://p2library.nfesc.navy.mil/index.htm

NPDES-permitted industrial point source discharges

Participate in basinwide management plans that allow tradeoffs for maximum ecological and economic benefits (Great Lakes and Chesapeake Bay programs are examples of major holistic plans) Involve community, schools, and other citizens in water sampling

DoD Joint Services P2 Library at http://p2library.nfesc.navy.mil/index.htm EPA Industrial Activities at http://www.cfpub.epa.gov/npdes/ stormwater/indust.cfm EPA BMP database at http://www.bmpdatabase.org/ Air Pollution Prevention (P2) Guide at https://www.denix.osd.mil/denix/DOD/ Library/Air/Airmgt/aqtoc.html

Non-permitted mobile sources

Establish shared and alternative transportation programs to reduce air emissions, traffic congestion, and conserve energy Increase use of parking spaces and pedestrian crossings

Watershed Impact Assessment Guidance for Public Lands and Facilities

5-8

Select Mitigation Projects for High Priority Activities

Exhibit 5-1. Typical BMPs and Mitigation Efforts for High Priority Activities (Continued)
Typical activity
NPDES storm water discharges

Typical mitigation activities
Implement stormwater BMPS, including bioengineered and low impact development approaches that combine hydrologically functional site designs with pollution prevention measures to reduce negative impacts on hydrology and water quality. (Low impact development projects apply a “natural remedy” to prevent potential problems, thereby reducing high costs of some conventional types of construction techniques)

References for additional BMP data
EPA’s Office of Wastewater’s Storm Water BMP Fact Sheets at http://www.cfpub.epa.gov/npdes/ stormwater/menuofbmps.cfm State of Maryland Storm Water BMP Design Manual at http://www.mde.state.md.us/ environment/wma/stormwatermanual/ index.html Low Impact Development Center at http://lowimpactdevelopment.org/ EPA Industrial Activities at http://www.cfpub.epa.gov/npdes/ stormwater/indust.cfm Planning and Design Manual for the Control of Erosion, Sediment, and Stormwater at http://abe.msstate.edu/csd/ pdm/index.html

Paved roads, parking lots, railroads, curbs, and sidewalks

Use low impact development technologies Replace impervious materials with pervious materials (such as permeable pavers or pavement) Install sand filters to treat stormwater runoff from large buildings, access roads, and parking lots Eliminate curbs Treat runoff in vegetated swales Increase pervious areas—replace shoulder area with pervious materials such as gravel

Low Impact Development Center at http://lowimpactdevelopment.org/ The Stormwater Manager’s Resource Center at http://www.stormwatercenter.net/

Permitted stationary sources

Implement air pollutant control BMPs

Air Pollution Prevention (P2) Guide https://www.denix.osd.mil/denix/DOD/ Library/Air/Airmgt/aqtoc.html DoD Joint Services P2 Library at http://p2library.nfesc.navy.mil/index.htm

Watershed Impact Assessment Guidance for Public Lands and Facilities

5-9

Exhibit 5-1. Typical BMPs and Mitigation Efforts for High Priority Activities (Continued)
Typical activity
Septic systems or Class V wells

Typical mitigation activities
Recycle and reuse wastewater Collect and recycle petroleum-based fluids, coolants, and battery acids drained from vehicles Wash parts in self-contained, recirculating solvent sink, with spent solvents being recovered and replaced by the supplier Use absorbents to clean up minor leaks and spills and place used materials in approved waste containers, disposing of them properly Use a wet vacuum or mop to pick up accumulated rain or snow melt Regularly pump, inspect, and maintain wells Connect floor drains to permitted publicly owned wastewater treatment plant Replace with advanced treatment technologies or hook up to POTW

References for additional BMP data
EPA at http://www.epa.gov/safewater/uic/ classv.html Minnesota's Individual Treatment Systems Program at http://www.pca.state.mn.us programs/lsts/index.html EPA BMPs Class V wells at http://www.epa.gov/seahome/inject/ src/best.htm Rhode Island Checkup at http://www.state.ri.us/dem/pubs/regs/ regs/water/isdsbook.pdf

Unpaved and service roads

Keep vegetative cover Conduct scheduled maintenance of grounds Use environmentally friendly low-water crossing designs

EPA’s Recommended Practices Manual: A Guideline for Maintenance and Service of Unpaved Roads at http://www.epa.gov/owow/nps/ unpavedroads.html Road Management & Engineering Journal at http://www.usroads.com/journals/rmej/ 9806/rm980604.htm Seneca Mineral at http://www.senecamineral.com/ dustcontrolproducts.htm Corps of Engineers Construction Engineering Research Laboratory Soil and Erosion Control at http://www.cecer.army.mil/td/tips/ products/details.dfm?ID=489&TOP=1

Underground storage tank (UST) leaks

Meet UST requirements—certify that tanks and piping are installed properly according to industry codes; install devices that prevent spills and overfills; protect tanks and piping from corrosion; and install leak detection systems

DoD Joint Services P2 Library at http://p2library.nfesc.navy.mil/ index.htm

5-10

Watershed Impact Assessment Guidance for Public Lands and Facilities

Select Mitigation Projects for High Priority Activities

Exhibit 5-1. Typical BMPs and Mitigation Efforts for High Priority Activities (Continued)
Typical activity
Water supply or ground water withdrawal wells treatment

Typical mitigation activities
Consider the effects of the cone of depression on adjacent users and uses Consider the downstream effects of the pumped water and soil salinity Implement water conservation efforts, including facility and grounds areas

References for additional BMP data
U.S. Army Source Water Protection Guide at http://water.usgs.gov/usaec/ EPA’s general BMPs at http://www.epa.gov/seahome/inject/ src/gbest.htm

Watershed Impact Assessment Guidance for Public Lands and Facilities

5-11

THIS PAGE INTENTIONALLY LEFT BLANK

5-12

Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter 6 Develop Project Partnerships
6-1 Introduction
Many municipalities are short staffed and have too many initiatives and too little funding. Developing partnerships can help you accomplish your projects cost-effectively. Municipalities can partner with regulators, other municipalities, federal agencies, state and local governments, and citizen groups to accomplish various environmental objectives, share resources, access expertise, and resolve regulatory issues. In addition, public works offices can partner with other municipal offices, such as emergency management, to accomplish complex or integrated projects.

6-2 Why Form Partnerships?
A partnership is the easiest way to develop and implement successful projects because everyone is involved from the onset. This upfront involvement means the ultimate plan will truly have the consensus of all parties with a stake in the watershed and assets. In general, forming partnerships with others can help do the following: Lower project costs. If other parties are already involved in the project, you can reduce the time it takes for approvals, improve logistical support, and obtain volunteer labor or technical assistance. Saving time also means saving money. Build good community relations. Partners relay their positive experiences to others within the community. Build advocates for your program. Other municipal offices or the public can be powerful advocates for change if involved from the beginning of projects.

Watershed Impact Assessment Guidance for Public Lands and Facilities

6-1

Obtain additional funds (subject to county and state fiscal legal restraints). Other offices, federal agencies, state and local governments, local businesses, or citizen groups may be interested in sharing costs on projects. Receive grants and awards. EPA, state agencies, and other organizations offer grants and awards to help promote watershed management. Coordinate volunteers to conduct monitoring, stream cleanup, and stream or watershed restoration days. Provide technical expertise for demonstration projects. Coordinate and conduct field trips and tours. Establish and run meetings and workshops. Develop focus groups. Conduct opinion surveys. Provide media relations. Support and develop educational programs for schools, civic groups, and other local organizations. Partnerships can be challenging: it takes time and skill to create successful ones. Maintaining motivation and enthusiasm is another challenge, especially if positive results do not happen quickly. All relevant stakeholders must believe their efforts are necessary. As you build partnerships, you will encounter these and other challenges. Keep in mind, however, that the benefits of partnerships usually far outweigh the challenges.

6-3 What Are the Steps?
There are some basic steps in forming and building partnerships: Identify opportunities that lend themselves to partnering. Identify potential partners. Develop partnerships. Collaborate to implement the projects. Share success and praise with outside stakeholders.

6-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Develop Project Partnerships 6-3.1 Identify Opportunities The first step is to identify opportunities for partnering. By completing the forms, you have already identified activities and solutions that could benefit from partners. 6-3.2 Identify Potential Partners Ways to identify potential project partners vary. For example, EPA and a variety of non-governmental organizations have developed a catalog of organizations involved in protecting local waterbodies, including government agencies, formal watershed alliances, national groups, local groups, and schools that conduct activities such as volunteer monitoring, cleanups, and restoration projects. In addition, many websites offer access to organizations that can assist your efforts: EPA hosts a Catalogue of Watershed Groups website at http://www.epa.gov/adopt/network.html. This website contains the group name and Internet site (if available); contact name, address, e-mail address, and phone number; watershed and locations of interest; description of activities; and number of volunteers. EPA hosts the River Corridors and Wetlands Restoration (RCWR) Partnership, at http://www.epa.gov/owow/wetlands/ restore/rpart.htm. The RCWR partnership is an ad hoc team consisting of public agencies and private organizations that engage in wetland and watershed restoration efforts, share information, and find opportunities for collaboration. The team promotes and supports community-based projects that improve the quality of life of the community and the health of its watersheds. EPA recognizes that restoration efforts require a team approach and welcomes any national organization with similar interests to join the RCWR partnership. You can use Exhibit 6-1 as a template for tracking potential regional partners (refer to http://www.epa.gov/win/contacts.html). You can use Form 2, Block 8, if you want to track potential partners at a projectspecific level.

Watershed Impact Assessment Guidance for Public Lands and Facilities

6-3

Exhibit 6-1. Regional Partnering Template
Project Partnering Opportunity Template
Project title: Project description:

Municipal project lead office Municipal project lead office: Contact phone:

Point of contact name:

Contact e-mail:

List potential regulatory agency, citizen group, other partners Contact phone/ e-mail:

Organization name:

Point of contact:

POC address:

Potential role in project:

6-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Develop Project Partnerships 6-3.3 Develop Partnerships Successful partnerships should include the following key elements: Clear communication of objectives and identification of opportunities for shared interests in project write-ups and execution. Establishment of clear roles and responsibilities. A written agreement between partners. For detailed guidance on building local partnerships, review Building Local Partnerships: A Guide for Watershed Partnerships at the Know Your Watershed website of the Conservation Technology Information Center at www.ctic.purdue.edu/KYW/Brochures/BuildingLocal.html. 6-3.4 Collaborate to Implement Projects The next step is to collaborate with the identified partners to implement projects. 6-3.5 Share Success and Praise with Outside Stakeholders The last step is to share the success of the partnership effort and project success with outside stakeholders.

6-4 Working with Other Municipalities
Just as important as forming partnerships with citizen groups, is the formation of a good working relationship with other municipalities. You can work with other municipalities to obtain technical assistance, establish standard approaches, and share resources.

Summary
You can and should participate in the TMDL determination process. Your completed forms provide all the necessary information for the TMDL determination process.

6-5 Working with Regulators
You can work with your state and local regulators to determine appropriate TMDLs and establish and participate in an effluent trading program. 6-5.1 Working with Regulators During TMDL Determinations Municipalities may have the opportunity to work with EPA and state regulatory officials during the state TMDL determination process. A TMDL provides the water quality analysis and planning process for determining the specific pollution reductions necessary to attain or maintain water quality standards. The TMDL process includes legal requirements for public participation and implementation through NPDES permits.

Watershed Impact Assessment Guidance for Public Lands and Facilities

6-5

By working with regulators during the TMDL determination process, you may have the opportunity to negotiate a tradeoff between reduced NPDES point source permit limits with changes in land management or non-point source management practices. Therefore, you can and should participate in the TMDL determination process. Your completed forms provide all the necessary information for the TMDL determination process. 6-5.2 Working with Regulators to Establish Effluent Trading Since the early 1990s, EPA has been promoting the use of effluent trading to achieve water quality objectives and standards within watersheds. EPA issued a Final Water Quality Trading Policy in 2003,1 which encourages states, interstate agencies, and tribes to develop and implement water quality trading programs for nutrients, sediments, and other pollutants where opportunities exist to achieve water quality improvements at reduced costs. More specifically, the policy encourages voluntary trading programs that facilitate implementation of TMDLs, reduce the costs of compliance with CWA regulations, establish incentives for voluntary reductions, and promote watershed-based initiatives. A number of states are in various stages of developing trading programs. To take advantage of trading, you must have a point source that is in compliance and remains in compliance with applicable technologybased limits. Intra-plant trades must also have a technology-based floor, while the technology floor for pretreatment trading is determined by the categorical standards. EPA expects that most trades will be covered by TMDL or similar watershed-based analysis. The items you can trade are the pollutant reductions or water quality improvements. Under trading, a source that can more cost-effectively achieve greater pollutant reduction than is otherwise required would be able to sell or barter the credits for its excess reduction to another source unable to reduce its own pollutants as cheaply. To ensure that water quality standards are met throughout a watershed, an equivalent or better water pollutant reduction would need to result from a trade. EPA’s implementation framework for effluent trading under the TMDL program is a companion to its effluent trading policy. It encourages trading and assists in evaluating and designing trading programs. The framework provides the following: Background information on effluent trading and its benefits. The conditions necessary for trading, including those that ensure protection of water quality comparable to the protection that would be provided without trading.
The Final Water Quality Trading Policy can be downloaded from the EPA website at http://www.epa.gov/owow/watershed/trading/tradingpolicy.html.
1

6-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Develop Project Partnerships A template of regulatory, economic, data, technical, scientific, administrative, accountability, and enforcement issues that facilitate identification and evaluation of trading opportunities. Worksheets and checklists to evaluate whether potential trades meet threshold conditions. You can download a copy of this framework from the EPA’s website at http://www.epa.gov/owow/watershed/trading.htm.

Watershed Impact Assessment Guidance for Public Lands and Facilities

6-7

THIS PAGE INTENTIONALLY LEFT BLANK

6-8

Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter 7 Implement Solutions and Track Progress
The last phase of the watershed assessment process includes implementing the identified solutions, tracking their progress, and updating your projects as required. Implementation is the “doing” stage, a critical component of watershed restoration. It brings together all of the activities necessary to reach your watershed restoration goals and puts them to work.

Tip
Review your plan at least annually to reassess and reprioritize your projects.

7-1 Planning and Budgeting for High Priority Projects
To implement watershed restoration projects and activities, you must budget the funds needed to obtain equipment, provide training, perform services, and conduct specific projects under the plan. Your watershed assessment plan should cover at least 8 years. However, the plan will be implemented based on the priority of projects and initiatives identified as well as the funds available for implementation. Therefore, you should review and update your plan at least annually to reassess and reprioritize projects. 7-1.1 Estimating and Submitting Project Costs For every project you want to implement (regardless of its funding source), you need to develop a cost estimate for budgeting and requesting funds. Appendix E contains a description of potential BMP websites, which cover associated unit cost factors for some projects. 7-1.2 Integrate Project in Municipal Budget The next step in implementation is incorporating your projects into the municipal budget as part of strategic asset management. Selecting projects for funding is largely a subjective process, with tight budgetary limits, and often influenced by politics. Municipalities may use return on investment and total costs to select watershed restoration projects as part of their infrastructure budget. However, developing an infrastructure budget is not an exact science. Exhibit 1-3 shows an assessment of the

Watershed Impact Assessment Guidance for Public Lands and Facilities

7-1

budgeting attractiveness of infrastructure investments on the basis of return on investment and total cost. 7-1.3 Identify Available Funding Sources Municipalities can implement desirable projects that are not included in the budget by identifying and developing partnerships with other stakeholders. Form 6 allows you to list partners, agreements, benefits, addresses, and points of contact for tracking purposes. This guide provides links to groups active in each watershed around the country as well as types of groups that may provide assistance and support. Chapter 6 has a partnership template for tracking regional and project partners. 7-1.4 Update Zoning and Ordinance Requirements Municipalities will need to evaluate and potentially update zoning and ordinance requirements to implement some watershed restoration projects.

7-2 Sources of Funds for Identified Projects
The funds you need to accomplish the projects you have identified can come from four sources: municipal budget funds, other municipal funding sources, partnerships, and outside sources (including federal funding). The following publications are other sources of funding information related to wetlands and watersheds: Catalog of Federal Funding Sources for Watershed Protection: Second Edition. The catalog (EPA841-B-97-008) includes funding source descriptions and department and agency statute and title indexes. It is available on the EPA’s Watershed Academy website at http://www.epa.gov/OWOW/watershed/ wacademy/fund.html. The website also offers online education and training for a wide range of issues related to watersheds. EPA’s Watershed Information Network’s (WIN) List of Federal Catalogs of Financial Assistance. This website contains links to over 20 different references. It is available through the WIN website at http://yosemite.epa.gov/water/surfah.nsf/ financial? OpenView&Start=1&Count=30&Expand=1 - 1. Funding for Habitat Restoration Projects: A Compendium of Current Federal Programs with Fiscal Year 1996–1999 Funding Levels: A Citizens Guide. Updated versions are available at http://www.estuaries.org/funding.html. The listings include the type of support, authorities, funding levels, activities, and eligibility requirements.

7-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Implement Solutions and Track Progress River Restoration and Community Revitalization: A Digest of Select Federal Programs for Rivers. This digest is published by American Rivers, Inc., and is available through their website at http://www.amrivers.org, or by e-mailing them at amrivers@amrivers.org. The booklet includes descriptions and contact information for select federal programs that involve river restoration (directly or indirectly). It features case studies for cities currently engaged in funded projects. An Introduction to Wetland Restoration, Creation, and Enhancement. This document was developed by the Interagency Workgroup on Wetland Restoration, which includes EPA, National Oceanic and Atmospheric Administration, Army Corps of Engineers, Fish and Wildlife Service, and Natural Resources Conservation Service. The guide includes technical resources, contacts, and funding sources. The document is available at http://www.epa.gov/owow/wetlands/restdocfinal.pdf.

7-3 Obligating Funds, Developing Scopes of Work, and Letting Contracts
The following steps summarize the process of obligating funds through an existing mechanism: Step 1: Identify a potential mechanism for obligating funds. This can include an existing contract or cooperative agreement. You should have a copy and understand its provisions fully. Step 2: Understand all relevant review and approval procedures. For example, approval for a project may require a series of reviews through the municipal organization. Step 3: Notify your accounting and finance office. Once a project has been approved for funding, the accounting and finance office requires advance notice of your intention to obligate funds. You must obtain certification of funds available before you can contract for services or obligate funds. Note where funds will be transferred from other offices to the installation. Step 4: Prepare a statement of work (SOW). The SOW describes the types of work to be performed and materials to be used or submitted. It should identify the point of contact within the military and contractor's organization and should specify the period of performance and specific deliverables. You may want to obtain and review good models or examples of other SOWs from your contracting office that have been prepared for the type of project you are considering.

Watershed Impact Assessment Guidance for Public Lands and Facilities

7-3

Step 5: Verify that funds are available. Ensure that the accounting and finance office has control of the funds you plan to obligate. Step 6: Submit the form to transfer funds for obligation. Obtain the appropriate form from your accounting and finance office that will formally commit funds obligated by contract. Funds are not obligated until the receiving organization acknowledges receipt of the funding document. Again, you should ensure that the legal office and contracting office guide you through this process. You should anticipate that the obligation of funds may require 6 weeks or more from the time funds are certified and the contracting office gets an acceptable SOW. When a suitable contracting mechanism is unavailable, you may want to consider a source selection process to obtain the services of a contractor. Keep in mind that this is a complex and time-consuming process, which can take 6 months or more to complete. Should you choose this avenue, we strongly advise against third-party contracting or other arrangements that create distance between you and the contractor. Remember, when managing government funds, only certain individuals have the authority to obligate funds. The contractor cannot begin work until contracts have been finalized and funds are obligated. If you are the point of contact or project manager for the government, you are responsible for monitoring the contractor's technical progress. You should ensure that you have obtained all necessary training and guidance required to perform this role.

Summary
Tracking and monitoring your watershed assessment plan’s efforts are central to maintaining accountability, documenting what you have done, and demonstrating that your efforts have been thoughtful and responsible.

7-4 Produce Summary Reports to Track Projects
A final consideration when implementing your watershed restoration projects is measuring success, reporting, and sharing information. Tracking and monitoring progress toward watershed goals and objectives also allows you to adapt to feedback from monitoring efforts and reprioritize projects, if necessary. These types of efforts are central to maintaining accountability, documenting what you have done, and demonstrating that your efforts have been thoughtful and responsible.

7-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

7-5 Maintaining and Updating Your Watershed Restoration Projects
Watershed management is a critical dimension of strategic asset management. Optimizing environmental condition and asset valuation is not a one-time event; municipalities should continually evaluate watershed conditions and potential watershed restoration projects to maximize asset value. At a minimum, municipalities should conduct this Municipal Watershed Impact Assessment Process annually to prioritize, budget, and reallocate priorities as necessary. Evaluating your management actions and using monitoring information to readjust project priorities and initiatives is proactive management; proactive management is integral to watershed and strategic asset management and is the reason for inherent flexibility in implementing this process. Most goals and objectives may be relatively set, but how and when you achieve them are subject to many internal and external forces. Keeping an updated list of watershed restoration project priorities helps newly elected officials, managers, staff, and others quickly assess the status of environmental compliance and the asset management program. An updated priority list also feeds directly into the planning and budgeting processes and helps identify successes as well as failures. Use the information from your tracking and monitoring data to determine what needs to be updated and reprioritized. Monitoring data may indicate that some initiatives need to be reallocated to subsequent funding years, placed on accelerated schedules, or shelved indefinitely. External issues—such as increases in development, reprogramming of funds, or new compliance requirements—may also require you to reprioritize projects and adjust your budget requests. A review of monitoring data may also indicate that a particular objective has not yet been met and that follow-on steps should not be initiated as originally scheduled in the plan. Even climate or weather conditions can adversely affect project and initiative implementation

Tip
An updated list of priorities has the following benefits:

Newly elected officials, managers, staff, and others can quickly assess the status of environmental compliance and the asset management program. It links to the planning and budget processes. It helps in monitoring successes and failures.

Watershed Impact Assessment Guidance for Public Lands and Facilities

7-5

THIS PAGE INTENTIONALLY LEFT BLANK

7-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix A Abbreviations
ABIS AIS ASAP AST BMP BOD CAA CERCLA COD CWA CWAP CZA DoI CZMA ECMP EMS EO EPA EPCRA ESA FIFRA GIS GMP HUC ID LID MNS MOU NASA NCA NEPA NHD NHPA NMFS activity baseline impact score activity impact score Army Sampling and Analysis Plan for Small Arms Ranges above ground storage tank best management practice biological oxygen demand clean air act Comprehensive Environmental Restoration, Compensation and Liability Act chemical oxygen demand clean water act clean water action plan Coastal Zone Act Department of Interior Coastal Zone Management Act erosion control management plan environmental management system executive order Environmental Protection Agency Emergency Planning and Community Right-to-Know Act Endangered Species Act Federal Insecticide, Fungicide, and Rodenticide Act geographic information system grounds management plan Hydrological Unit Code identification low-impact development mission need score memorandum of understanding National Aeronautics and Space Administration Noise Control Act National Environmental Policy Act national hydrography dataset National Historic Preservation Act National Marine Fisheries Service

Watershed Impact Assessment Guidance for Public Lands and Facilities

A-1

NPDES NPS O&M P2 POL RCRA RCWR SDWA SOx SPCC SVOC SW SWAP TABS TMDL TRI TSCA TSS UIC USFWS UST UWA VOC WATER WPS WSS

National Pollutant Discharge Elimination System nonpoint source or National Park Service operation and maintenance pollution prevention petroleum, oil, and lubricant Resource Conservation and Recovery Act River Corridors and Wetlands Restoration Safe Drinking Water Act sulfur oxides spill prevention, control and countermeasures semivolatile organic chemical stormwater source water assessment and protection total activity burden score total maximum daily load toxic release inventory Toxic Substances Control Act total suspended solids underground injection control United States Fish and Wildlife Service underground storage tank Unified Watershed Assessment volatile organic compound Watershed Assessment, Tracking & Environmental Result watershed priority score watershed sensitivity score

A-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix B Laws Affecting Watershed Management
This appendix provides a summary (and links to additional information) of key federal laws governing water resources (http://www.epa.gov/ win/law.html) in the United States that provide the basis for watershed protection activities, as well as information that can be used for protecting a watershed. For each item, we provide a summary of the legislation, its impact or relationship with watershed planning, and links to additional information.

Clean Water Act
The Federal Water Pollution Control Act, or Clean Water Act (CWA) (full text can be located at http://www.epa.gov/win/law.html), is the principal law governing pollution in the nation’s streams, lakes, and estuaries. Originally enacted in 1948, it was totally revised by amendments in 1972 (P.L. 92-500) that gave the act its current form and spelled out ambitious programs for water quality improvements that are now being put in place by industries and cities. Congress made certain fine-tuning amendments in 1977 (P.L. 95-217) and 1981 (P.L. 97-117). The CWA prohibits the discharge of any pollutant to waters of the United States from a point source unless the discharge is authorized by a National Pollutant Discharge Elimination System (NPDES) permit. The NPDES permitting program is designed to track point sources, monitor the discharge of pollutants from specific sources to surface waters, and require the implementation of the controls necessary to minimize the discharge of pollutants. Initial efforts to improve water quality under the NPDES program primarily focused on reducing pollutants in industrial process wastewater and discharges from municipal sewage treatment plants. As pollution control measures for managing these sources were implemented and refined, studies showed that more diffuse sources of water pollution were also significant causes of water quality impairment, specifically, stormwater runoff draining large surface areas, such as agricultural and urban land. This fact led the EPA to adopt a watershed approach that is based on determining the total maximum daily load (TMDL) of a particular pollutant that a waterbody can accept and still meet its water quality standards.

Watershed Impact Assessment Guidance for Public Lands and Facilities

B-1

The Basis for Watershed Management Efforts—Water Quality Standards and Total Maximum Daily Loads
EPA’s TMDL program is the main driver behind the adoption of watershed approaches to managing water issues. Under CWA Section 303(d), states are required to identify waters that do not meet water quality standards—even after the implementation of nationally required levels of pollution control technology. The law further requires states to develop TMDLs (with oversight from Environmental Protection Agency (EPA)) and establish a priority ranking for the identified impaired waters. These TMDLs allocate pollutant loadings among pollution sources in a watershed and provide a basis for identifying and establishing controls to reduce both point source and nonpoint source (NPS) pollutant loadings. Water quality standards are a fundamental component of the CWA and, specifically, watershed management. These standards are adopted by states and tribes to protect public health; restore chemical, physical, and biological integrity of waters; and provide water quality for the protection and propagation of fish and wildlife and for recreation (“fishable/swimmable”). Standards consider the use and value of state and tribal waters for public water supplies, agricultural and industrial purposes, and navigation. Water quality standards depend on the designated uses of the water body and are based on water quality criteria established by EPA. State TMDL programs are required to use all “existing and readily available” information in developing Section 303(d) lists. This information may include source water assessments and endangered species act information. For example, since TMDLs are developed for specific pollutants or stressors, identification of these pollutants as a result of a source water assessment could provide an important indicator to states for verifying the need for developing a TMDL. States prepare section 303(d) lists that identify waters not meeting water quality standards because of a particular pollutant or stressor. This type of information is helpful for identifying contaminants of concern for watersheds and source waters (refer to EPA’s website—http://www.epa.gov/owow/tmdl/—for 303(d) lists, by state, of impaired waters). TMDLs for particular water bodies generally provide more detailed information about the sources of the pollution and can be used to develop allocation scenarios for pollutant loadings among pollution sources in a watershed. State TMDL programs are generally managed by state water quality agencies. At the local level, a variety of stakeholders may be involved including local and regional governing agencies, point sources, farmers, foresters, land developers, city and state planners, and local environmental organizations. For the latest status on the federal TMDL program, visit EPA’s homepage—http://www.epa.gov/owow/tmdl/ index.html.

B-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Laws Affecting Watershed Management

Managing Stormwater Discharges Through NPDES Permits
The 1987 amendments to the CWA mandated that EPA develop a tiered implementation strategy for the NPDES Stormwater Program. The second phase of the strategy was the Final Stormwater Phase II Rule, which was signed by Administrator Browner on October 29, 1999, and published in the Federal Register on December 8, 1999. The rule regulates two classes of storm water dischargers on a nationwide basis: Operators of small MS4s located in urbanized areas as defined by the Bureau of the Census (termed a “regulated” small MS4). A “small” MS4 is any MS4 not already covered by Phase I of the NPDES stormwater program. Waivers from coverage are available. Operators of construction activities that disturb equal to or more than one and less than five acres of land. Waivers from coverage are available. Additional small MS4s (outside of urbanized areas) and construction sites (disturbing less than one acre of land), along with other sources that are significant contributors of pollutants to U.S. waters (e.g., as identified via a TMDL process), may be brought into the NPDES Stormwater Program by the NPDES permitting authority. Operators of Phase II regulated small MS4s and small construction activities are required to apply for NPDES permit coverage (most under a general rather than an individual permit) and implement stormwater discharge management controls (often referred to best management practices (BMPs)) that effectively reduce or prevent the discharge of pollutants into receiving waters. The Phase II rule also revised the Phase I stormwater regulation. Specifically, EPA revised the original no exposure provision, found at 40 Code of Federal Regulations (CFR) 122.26(b)(14), to be a conditional exclusion. This conditional exclusion applies to all categories of industrial activity (except construction activity) with no exposure of industrial materials and activities to storm water. The Phase II revision, found at Section 122.26(g), requires industrial operators claiming no exposure to submit written certification that a condition of no exposure exists at their facility/site. The final rule includes a No Exposure Certification Form that is intended to serve as the required written certification in areas where EPA is the NPDES permitting authority. For more information concerning the no exposure revision, see the Stormwater Phase II Rule: Conditional No Exposure Exclusion for Industrial Activity fact sheet located on the EPA web site at (cfpub.epa.gov/npdes/stormwater/ swphases.cfm), or call EPA’s Stormwater Phase II Rule Hotline at (202) 260-5816, or send an e-mail to sw2@epa.gov.

Watershed Impact Assessment Guidance for Public Lands and Facilities

B-3

Nonpoint Source Controls
Section 319 of the CWA delegates the regulation of NPS pollution to the states and establishes the Nonpoint Source Management Program. EPA recognized the need for greater federal leadership to help focus state and local NPS efforts. Under Section 319 of the 1987 CWA amendments, states are: required to conduct statewide assessments of their waters to identify those that were either impaired (did not fully support state water quality standards) or threatened (presently meet water quality standards but are likely not to continue to meet water quality standards fully) because of NPS pollution; required to develop NPS management programs to address the impaired or threatened waters identified in their nonpoint assessments; and entitled to receive annual grants from EPA to assist them in implementing their NPS management programs once EPA had approved the assessments and programs. Although Section 319 does not include an enforcement mechanism to ensure that states actually develop and implement programs, CWA Section 303 requires that states identify all activities that cause a waterbody to be impaired—including NPSs—and develop mitigation plans. This provision enables the states to regulate the runoff from NPSs of pollution. These requirements are explained in the Proposed Federal Consistency Guidelines, which can be downloaded from the EPA website at http://www.epa.gov/owow/nps/Section319/ 319guide03.html. State NPS pollution control programs vary considerably. Most states encourage landowners to adopt voluntary NPS control methods. Some states, including North Carolina, New Jersey, Hawaii, and Washington, require consideration of NPSs through detailed erosion control plans and implementation of BMPs for ground-disturbing activities. North Carolina, for example, requires erosion control plans 30 days before any land-disturbing activities are started. Other states have empowered local jurisdictions to create and enforce their own erosion control measures.

Wetlands Program
Section 404 of the CWA, which is administered by the U.S. Army Corps of Engineers, establishes a program to regulate the discharge of dredged or fill material into U.S. waters. While the Section 404 program regulates the discharge of dredged or fill material on a case-by-case basis, provisions found within this authority can allow for the regulation of aquatic resources in a more comprehensive manner. Some examples include watershed planning, special area management planning, and advanced identification.

B-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Laws Affecting Watershed Management EPA’s wetlands program attempts to integrate wetlands protection into existing EPA programs (e.g., CWA). In addition, some states have developed or are developing State Wetlands Conservation Plans to provide a framework for integrating wetland programs across many state programs. EPA’s wetlands program has experience in providing assistance for the development of comprehensive wetlands plans, participating in efforts to develop such plans, and reviewing plans for other state and local programs. Wetland protection programs often need to assess the overall health of watershed ecosystems in order to estimate the impacts of proposed man-made changes. Assessments undertaken by federal, state, and local governments for protecting wetlands can provide information that may be useful for watershed assessments. Wetlands can provide a wide range of different functions and benefits to local communities, including the interception and filtration of pollutants, thereby improving source water quality and possibly reducing treatment costs. Constructed wetlands can improve source water quality for downstream rivers. Integrating wetlands protection and restoration into watershed programs can highlight the importance of targeting wetlands as high priority areas for protection and can reduce duplication of efforts and conflicting actions. More information is available at http://www.epa.gov/owow/wetlands/.

Spill Prevention, Control, and Countermeasure Requirements
The CWA also includes provisions to prevent spills of certain substances from reaching navigable waters. Section 311 of the CWA provides EPA and the U.S. Coast Guard with the authority to establish a program for preventing, preparing for, and responding to oil spills that occur in navigable waters of the United States. EPA implements provisions of Section 311 of the CWA through a variety of regulations, including the National Contingency Plan and the Oil Pollution Prevention regulations. As a cornerstone of its strategy to prevent oil spills from reaching our nation’s waters, the EPA requires that certain facilities develop and implement oil spill prevention, control, and countermeasures (SPCC) plans. Unlike oil spill contingency plans that typically address spill cleanup measures after a spill has occurred, the goal of an SPCC plan is to ensure that facilities put in place containment and other countermeasures to prevent oil spills from reaching navigable waters. Under EPA’s Oil Pollution Prevention regulation, facilities must detail and implement spill prevention and control measures in their SPCC plans. A spill contingency plan is required as part of the SPCC plan if a facility is unable to provide secondary containment (e.g., berms surrounding the oil storage tank). These plans are an essential element of a watershed impact analysis and a source water impact analysis

Watershed Impact Assessment Guidance for Public Lands and Facilities

B-5

because they list the types, quantities, and spill controls for oils and hazardous substances stored at municipal facilities. Spills are also regulated under the Oil Pollution Act (OPA). The OPA was signed into law in August 1990, largely in response to rising public concern following the Exxon Valdez incident. The OPA increased penalties for regulatory noncompliance, broadened the response and enforcement authorities of the federal government, and preserved state authority to establish laws governing oil spill prevention and response.

Safe Drinking Water Act
Section 1453 of the Safe Drinking Water Act (SDWA), as amended in 1996, requires all states to complete assessments of their public drinking water supplies. By 2003, each state and participating tribe will delineate the boundaries of areas in the state (or on tribal lands) that supply water for each public drinking water system, identify significant potential sources of contamination, and determine how susceptible each system is to sources of contamination. These drinking water source protection areas include federal lands that support non-federally owned public water systems (PWSs) as well as non-federal lands that support federally owned PWSs. For each area, the source water assessments synthesize existing information about the sources of each drinking water supply to provide a national base line on the potential contaminant threats and help guide future watershed restoration and protection. Source water protection plans and wellhead protection are discussed in the following subsections.

Source Water Protection Plans
The SDWA Amendments of 1996 required states to develop Source Water Assessment and Protection (SWAP) programs. A SWAP program includes a strategic approach to conducting the source water assessments, delineates the area of influence from which a contaminant may enter a PWS, inventories sources of potential or known contaminants within the delineated zone, and determines the susceptibility of a PWS to such contaminants. Information needed for source water assessments may be available from watershed assessments conducted for other programs (such as TMDL assessments). SWAPs can be integrated into other watershed protection efforts like point and NPS pollution control, wetlands protection, waste management, air pollution, and pesticide management. This integration of efforts will allow various watershed stakeholders to look for opportunities to leverage limited resources to meet common goals. For more information about SWAP, see http://www.epa.gov/owow/watershed/.

B-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Laws Affecting Watershed Management

Wellhead Protection Program
The SDWA amendments of 1986 (P.L. 99-339) established the Wellhead Protection (WHP) program to protect the recharge areas of PWS wells from all sources of contamination. Like the SWAP, the WHP provides information municipalities need to develop an overall watershed baseline impact assessment.

Underground Injection Control Program (UIC)
If the regulator finds that an underground injection activity, such as a leaky septic system, is contributing to surface water quality concerns, the regulator can impose restrictions on the activity to prevent further environmental degradation.

Coastal Zone Management Act of 1972
The Coastal Zone Management Act was amended through the Coastal Zone Act Reauthorization Amendments (CZARA) of 1990 and P.L. 104150, and the Coastal Zone Protection Act of 1996. In 1990, as part of the CZARA, Congress required the 29 states with federally approved Coastal Zone Management Act programs to develop coastal NPS programs. These programs provide for implementation within coastal watersheds of management measures specified by EPA and incorporate policies and mechanisms, enforceable at the state level, to ensure implementation of the specified measures. EPA and the National Oceanic and Atmospheric Administration (NOAA) jointly approve the programs. For more information, see http://www.ocrm.nos.noaa.gov/ czm/.

Other Federal Laws
Clean Air Act The Clean Air Act (CAA) requires the prevention or control of air pollution from stationary and mobile sources. The CAA includes provisions for control of air toxins, acid rain, chloroflourocarbons (CFCs), and halons. It provides for a national air quality permit program and increased enforcement. CAA permits and air emissions inventories of stationary sources can assist in watershed planning by quantifying material that can enter the watershed via air deposition. These emission inventories provide excellent information about the sources of watershed pollutants that may be coming from air deposition. Comprehensive Environmental Response, Compensation, and Liability Act The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)—also known as the Superfund law—regulates the cleanup of leaking hazardous waste disposal sites. It also

Watershed Impact Assessment Guidance for Public Lands and Facilities

B-7

establishes liability for hazardous substance releases—producing facilities are liable for cleanup of their releases and restitution costs. Furthermore, states may identify clean up of these sites as applicable or relevant and appropriate requirements for its water quality standards. At the municipal level, restoration planning (CERCLA) documents provide a list and description of sites that are slated for restoration. When conducting a watershed baseline impact study, you should consider these sites as they may contribute, via runoff or ground water, to the impairment of a particular waterbody. Emergency Planning and Community Right to Know Act The Emergency Planning and Community Right to Know Act (EPCRA) requires personnel to participate in the emergency planning process. If a site has extremely hazardous substances (EHS) above its threshold planning quantities, EPCRA requires the site to notify and provide information to the local emergency planning committees (LEPCs) and state emergency response commissions (SERCs). The site must notify the SERCs and LEPCs if a CERCLA hazardous substance or EHS is released. EPCRA requires that site managers provide information to emergency planners and the public on hazardous substances used at the site, including the hazards posed by these chemicals and how they are handled on-site. A toxic release inventory (TRI) of toxic chemical releases must be conducted and submitted annually to EPA and the appropriate state agency (TRI Form R). This report must include information on the release and off-site transfer of toxic chemicals. EPCRA documents provide excellent information about the location of stored hazardous materials that should be incorporated into a watershed impact assessment document. Endangered Species Act The Endangered Species Act (ESA), 16 USC 1531 et seq., was enacted in 1973. The ESA establishes a procedural framework, substantive mandates, and prohibitions to ensure that it conserves species federally listed as threatened and endangered (T&E). Under the substantive mandates, a person is prohibited from undertaking actions that are likely to jeopardize a federally listed T&E species, destroy or adversely modify the designated critical habitat of such a species, or “take,” without authorization, a listed T&E species. Federal Insecticide, Fungicide, and Rodenticide Act The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (see 7 USC 136 as amended) and the Food Quality Protection Act of 1996 were promulgated to protect citizens from hazardous effects of pesticides. Enforcement authority for FIFRA rests with the EPA, which regulates the production, distribution, storage, use, and disposal of pesticides within the United States. (See 40 CFR parts 150–171.) FIFRA B-8 Watershed Impact Assessment Guidance for Public Lands and Facilities

Laws Affecting Watershed Management requirements that most influence current operations at municipalities are found in 40 CFR Part 171, which specifies certification requirements for pesticide applicators. FIFRA regulations for pesticide storage and disposal in 40 CFR 165 (subparts C and D) have been deleted and are superceded in part by regulations enacted under the Resource Conservation and Recovery Act (RCRA). Resource Conservation and Recovery Act RCRA, 42 USC 6901 et seq., was enacted by Congress in 1976 as a comprehensive regulatory program for the management of hazardous waste (HW) from “cradle to grave.” Under RCRA, HW is treated, stored, and disposed of in ways that minimize risk to human health and the environment. RCRA has been amended several times since its enactment, most importantly by the Hazardous and Solid Waste Amendments of 1984 (HSWA). The HSWA mandated changes to RCRA, such as HW minimization, land disposal restrictions, and provisions for regulation of underground storage tanks (USTs) that contain petroleum products or hazardous substances. HSWA provides management and technical standards for generators and transporters of HW and for owners and operators of treatment, storage, and disposal (TSD) facilities and USTs. RCRA operating permits and closure plans provide a list and description of sites that have discharges to groundwater, surface water, and to air. When conducting a watershed baseline impact study, you should consider these sites as they may contribute, via runoff or ground water, to the impairment of a particular waterbody. Furthermore, you should be aware that states may revise a RCRA operating permit or closure plan to establish stricter discharge limits if that site is identified as an activity causing an impairment to a waterbody. Toxic Substances Control Act The Toxic Substances Control Act (TSCA), 15 U.S.C. 2601 et seq., authorizes EPA to screen existing and new chemicals used in manufacturing and commerce to identify potentially dangerous products or uses that should be subject to federal control. As enacted, TSCA also included a provision requiring EPA to take specific measures to control the risks from polychlorinated biphenyls (PCBs) [Section 6(e)]. Subsequently, three titles have been added to address concerns about other specific toxic substances—asbestos in 1986 (Title II, P.L. 99-519), radon in 1988 (Title III, P.L. 100-551), and lead in 1992 (Title IV, P.L. 102-550). EPA may require manufacturers and processors of chemicals to conduct and report the results of tests to determine the effects of potentially dangerous chemicals on living things. Based on test results and other information, EPA may regulate the manufacture, importation, processing, distribution, use, and/or disposal of any chemical that presents an unreasonable risk of injury to human health or the environment. A variety of regulatory tools are available to EPA under

Watershed Impact Assessment Guidance for Public Lands and Facilities

B-9

TSCA ranging in severity from a total ban on production, import, and use to a requirement that a product bears a warning label at the point of sale. TSCA directs EPA to use the least burdensome option that can reduce risk to a level that is reasonable given the benefits provided by the chemical product or process.

B-10

Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix C List of Typical Municipal Activities
The following table provides a summary list of the typical municipal activities. Table C-1 contains a listing of typical activities and the environmental impacts typically associated with each.

Watershed Impact Assessment Guidance for Public Lands and Facilities

C-1

THIS PAGE INTENTIONALLY LEFT BLANK

C-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

List of Typical Municipal Activities

Watershed Impact Assessment Guidance for Public Lands and Facilities

C-3

C-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

List of Typical Municipal Activities

Watershed Impact Assessment Guidance for Public Lands and Facilities

C-5

C-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix D Data Entry Form for Typical Municipal Activities
The following tables provide a summary list of the typical municipal activities. Table D-1 contains a data entry form for recording the actual municipal activities and the environmental impacts typically associated with each.

Watershed Impact Assessment Guidance for Public Lands and Facilities

D-1

THIS PAGE INTENTIONALLY LEFT BLANK

D-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Data Entry Form for Typical Municipal Activities

Form 6. Municipal Activity Data Entry Sheet - Part 1
Part 1. Describe the Activity, its Potential Impacts, and Identify its Watershed or Waterbody
1. Name of activity: 2. Describe activity:

3. Location(s):

4. Responsible office:

5. Unique activity ID# or SIC#:

6. Describe current mitigation efforts and past restoration efforts (Existing or Planned):

7. Estimate annual cost of mitigation efforts:

8. Check the laws that regulate/permit the operation of the activity: □CWA □RCRA □CAA □SDWA □EPCRA □ NCA □NHPA

□TSCA □FIFRA □ESA □CZMA □ NEPA □ State:_________________________ □ Local:_________________________ □ Other:_________________________
10. Receiving waterbody name and 10 –12 level HUC #, Form 1: Pollutant of Concern 12. List the TMDL regulated pollutants or 303(d) listed pollutants of concern released by activity from Form 2 303(d) Impairment 1: 303(d) Impairment 2: 303(d) Impairment 3: 303(d) Impairment 4: 303(d) Impairment 5: 303(d) Impairment 6:
K/P Release nutrient Release BOD/COD Release inorganic Release metals Release POLs Uncontrolled storm water runoff Release pesticides K/P Release TSS Cause erosion Cause thermal pollution Release pathogens Disrupt potable supply Release explosives Potential spill Release VOC/SVOC K/P
th th

9. List required permits and plans: a. _______________________________ b. _______________________________ c. _______________________________ d. _______________________________

11. WPS from Form 2: TMDL? yes yes yes yes yes yes no no no no no no
K/P Release SOx to air Release NOx to air Hazardous air pollutants Greenhouse gas emission Release PM 10 to air Violate noise standards Decrease riparian buffer Introduce invasive species Decrease wetlands Decrease fish spawning range Cause in-stream scouring Cause flooding

Sampled

Estimated

13. Check activity’s other known or potential pollutant releases or impairments (Check K for Known or P for Potential and check all that apply.)

Watershed Impact Assessment Guidance for Public Lands and Facilities

D-3

Form 6. Municipal Activity Data Entry Sheet (Continued) - Part 2
Part 2. Quantify the Activity’s Impact and Determine the Total Activity Burden Score
Yes or known significant impact = 3 pts High probability or uncertain impact =2 pts No or negligible impact = 0 pt Low probability but uncertain impact =1 pt

Answer the following questions to develop the activity's impact score (AIS):
(Use your own professional judgment, technical studies, monitoring data, and the instructions to answer the questions.)

a. Does the activity result in a direct point source discharge to surface waters that is regulated under the CWA (do not include a discharge from storm water runoff in this question)? b. Is the activity out of compliance with CWA regulations because it does not have an individual permit or is NOT included on the municipal permit? c. If the activity is permitted, is it currently out of compliance with the permit standards? d. Has the activity had past recurring non-compliance with permit standards and/or conditions?

14. Surface Water Impact

e. Does the activity have a discharge of storm water runoff from a “regulated” point source? f. Does the activity have storm water runoff from non-point sources? g. Are the pollutants discharged from this activity to a surface water the same as those pollutants listed on the state/EPA 303d list (TMDL) for this waterbody? h. Does the activity drain to a waterbody that is a source of drinking water? i. Is the activity located in a state identified Source Water Protection Zone? j. Does the activity adversely affect flow of a waterbody with restrictions on water withdrawal or discharge volumes? a. Does the activity inject or have infiltration of a pollutant to groundwater? b. Does the activity discharge pollutants that violate drinking water maximum contaminant limits (MCLs) or water discharge permit limits to groundwater (if permitted)? c. Does the activity drain to groundwater that is a source of drinking water (aquifer or well)? d. Is the activity within 300 feet of a drinking water well or within a wellhead protection zone? a. Does the activity have non-permitted discharges to air that are also TMDL regulated pollutants?

15. Groundwater Impact

16. Air Quality Impact

b. Does the activity have a permitted discharge to air that is also considered a TMDL regulated pollutant? If so, is this air discharge in compliance with the CAA permit? Does the activity disturb sensitive/critical habitat or endangered species habitat? Does the activity adversely affect cultural resources or historic property? Does the activity discharge pollutant(s) that pose a risk to worker/public health and/or safety? a. Will a new municipal operation cause the activity to have a new pollutant discharge to water resources that will increase compliance requirements or liability?

17. Critical Habitat Impact 18. Cultural Resource Impact 19. Health and Safety Impact

20. Compliance Burden Impact

b. Does the activity require an environmental plan that requires management of discharges to water resources? If yes, has the plan been implemented? If so, has the plan been unsuccessful in reducing discharges of pollutants to water resources? c. Is the activity currently out of compliance with other environmental laws or regulations (e.g., RCRA, FIFRA, CERCLA) or has it had recurring non-compliance for any discharge, spill, or injection of a pollutant to water resources?

21. Identify other activity regulatory concerns or issues and rate the impact.

a. b.

22. AIS Sum scores from questions 14 to 21 23. Total Activity Burden Score (TABS) = AIS+WPS (from Form 2):

D-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Data Entry Form for Typical Municipal Activities Form 6. Municipal Activity Data Entry Sheet (Continued) - Parts 3–6
Part 3. Assess Potential for Pollution Prevention Opportunities
24. Activity’s Municipal Need Score. Select either 1 (the activity is unrelated to the municipality or municipal operations would not be adversely impacted at all if the activity ceased operations), 5 (the activity is somewhat related to the municipal or municipal operations would be slightly adversely impacted if the activity ceased operations), or 10 (the activity is critical to the municipal operations) 25. Calculate the activity’s current Burden to Municipal Need Ratio which equals the TABS from Block 23 / MNS from Block 24. [Higher ratios identify high burdens, but activities with lower importance. These activities are excellent candidates for the P2 evaluations listed in Block 26]. 26. Check the following P2 options that are appropriate for mitigating the impacts or compliance burden of the activity: eliminate activity consolidate activity outsource activity implement process change change materials 10 5 1

Part 4. Determine Project Objectives
27. Are enhanced mitigation efforts needed for this activity? Specifically, do you want to: a. Reduce the amount of pollutants entering receiving waters? b. Reduce runoff velocities or mimic predevelopment runoff flow volumes? c. Improve reliability and ease of maintenance of existing BMPs? d. Comply with permit requirements (for pollutant removal or flow control)? e. Reduce lifecycle costs of existing operations or BMPs? f. Restore natural habitat g. Other (describe)_____________________________________________________ yes yes yes yes yes yes yes yes no no no no no no no no

Part 5. Select Project BMP, Estimate Costs, and Source of Funds
28. Describe selected mitigation project or BMP: If yes to #27, provide title of proposed BMP or control technology: 29. Cost Data Estimated total startup costs a. Estimated planning, design & permitting costs b. Estimated purchase/construction costs Estimated O&M costs $

30. Estimate a reduction in TABS, assuming successful implementation of the enhanced mitigation effort uses the same scoring sheet as your original TABS (Part 2). Enter new TABS here. 31. Calculate cost effectiveness of proposed project = revised TABS score / total start costs 32. Provide reference to detailed project sheet 33. List most appropriate source of funds (e.g., O&M): 34. Is project eligible for other funds (e.g., state grants, EPA grants, grants from other organizations, etc.):

Part 6. Identify Project Lead and Potential Project Partners
35. Project lead office: 37. Point of contact name: 39. List potential partners Organization name: Point of contact: Contact phone: Role in project: 36. Contact phone: 38. Contact e-mail:

40. Attach a picture of the location, impairment, or activity
Form created by: Date form created: Form revised by: Date form revised:

Watershed Impact Assessment Guidance for Public Lands and Facilities

D-5

THIS PAGE INTENTIONALLY LEFT BLANK

D-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix E References for Best Management Practices
The following references provide a wide variety of best management practices that you can review when developing solutions to your identified impacts to a watershed.
General
Monitoring and assessment Indicators of performance

Best management practices
Cost information Location case studies Effectiveness Maintenance issues

General applicability

Title, description, and reference and WWW link
American Society of Civil Engineers (ASCE) National Stormwater BMP Database at website www.bmpdatabase.org. This www site contains an on-line database of BMPs that users can search based on type, pollutant treated or location used. For most cases, it presents detailed information on the effectiveness of each urban BMPs in removing pollutants. The database only contains studies that conform to established protocols. Center for Watershed Protection’s Stormwater Manager’s Resource Center. The Stormwater Manager's Resource Center is designed specifically for stormwater practitioners, local government officials, and others that need technical assistance on stormwater management issues. Created and maintained by the Center for Watershed Protection, the SMRC has everything you need to know about stormwater in a single site: http://www.stormwatercenter.net Also, the Center publishes the guide, titled Watershed Protection Techniques. Center for Watershed Protection, Silver Spring, MD. It can be ordered at http://www.cwp.org U.S. EPA provides a www site that contains a variety of stormwater and wastewater BMPs: http://www.epa.gov/seahome/inject/src/gbest.htm U.S. EPA, Nonpoint Source Pollution from Urban Sources BMP Resources, http://www.epa.gov/owow/nps/urban.html U.S. EPA, National Management Measures to Control Nonpoint Source Pollution from Marinas and Recreational Boating, http://www.epa.gov/owow/nps/mmsp/index.html U.S. EPA, National Management Measures to Control Nonpoint Source Pollution from Agriculture, Draft, http://www.epa.gov/owow/nps/agmm/index.html

x

Design information

Planning

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x x x x x x x x x x

x x x x

x x x x

x x x x

x x x x

x x x x x x x

Watershed Impact Assessment Guidance for Public Lands and Facilities

E-1

General
Monitoring and assessment Indicators of performance

Best management practices
Cost information Location case studies Effectiveness Maintenance issues

General applicability

Title, description, and reference and WWW link
U.S. EPA. January 1993. Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters. EPA 840-B-92-002. U.S. Environmental Protection Agency, Office of Water, Washington, DC U.S. EPA, 1998. Techniques for Tracking, Evaluating, and Reporting the Implementation of Nonpoint Source Control Measures - Urban Field Test Version. EPA841-B-937-011. Helps local officials focus limited resources by establishing statistical sampling to assess, inspect, or evaluate a representative set of BMPs, erosion and sediment controls, and on-site wastewater treatment systems U.S. EPA, 1997. Monitoring Guidance for Determining Effectiveness of Nonpoint Source Controls, Final. EPA/841B-96-004. U.S. EPA Nonpoint Source Control Branch. Addresses design of monitoring programs to assess water quality to determine impacts of nonpoint sources and effectiveness of practices used as controls Effects of Land Use Change on Hydrology and Nonpoint Source Pollution, Version 1.1, http://danpatch.ecn.purdue.edu/~sprawl/LTHIA2/ Horner, R.R., J.J. Skupien, E.H. Livingston, and H.E. Shaver. August 1994. Fundamentals of Urban Runoff Management: Technical and Institutional Issues. Terrene Institute, Washington, DC (in cooperation with U.S. EPA). (703) 548-5473 Livingston, Shaver, Horner, and Skupien, May 1997. Institutional Aspects of Urban Runoff Management: A Guide for Program Development and Implementation. The Watershed Management Institute, Inc. (WMI) (in cooperation with U.S. EPA), WMI (850) 926-5310. A comprehensive review of the institutional framework of successful urban runoff management programs at city, county, regional, and state levels of government. Recommendations are provided (based on surveys) that can help in all aspects of urban runoff program development and management Municipal Technologies, http://www.epa.gov/owmitnet/mtb/mtbfact.htm Maryland Stormwater Management BMP Design Manual, http://www.mde.state.md.us/environment/wma/stormwaterm anual/ Maine Department of Environmental Protection/MA Office of Coastal Zone Management, Stormwater Management Handbook, March 1997 Natural Resources Defense Council, May 1999. Stormwater Strategies: Community Responses to Runoff Pollution. Natural Resources Defense Council http://www.nrdc.org/water/pollution/storm/stoinx.asp

x

x

x

x

Design information

Planning

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x

x x x

x x x

x x x

x x x

x x x

x x x

x x x

x x x

x x x

x

x

x

x

x

x

x

x

x

E-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

References for Best Management Practices

General
Monitoring and assessment Indicators of performance

Best management practices
Cost information Location case studies Effectiveness Maintenance issues

General applicability

Title, description, and reference and WWW link
Prince George’s County, Maryland, Department of Environmental Resources Program and Planning Division, Low Impact Development Design Strategies: An Integrated Design Approach, January 2000 Services and Departments, http://www.slac.stanford.edu/esh/epr/stormwater.BMP1.html Terrene Institute. March 1996. A Watershed Approach to Urban Runoff: Handbook for Decisionmakers. Terrene Institute, Washington, DC (in cooperation with U.S. EPA Region 5). (703) 548-5473 or terriinst@aol.com. An informative primer for local decision makers and watershed organizations on assessing the water quality of watersheds, identifying contributing sources, and prioritizing watershed resources to implement effective nonstructural and structural BMPs. BMPs are summarized, and a list of resources to obtain additional information is provided U.S. Department of Agriculture (USDA). Award-winning interagency Stream Corridor Restoration Handbook www.usda.gov/stream_restoration USDA’s List of Agricultural Stormwater BMPs, http://www.ncg.nrcs.usda.gov/nhcp_2.html U.S. Natural Resources Conservation Service; various erosion control and streambank stabilization drawings. http://www.wa.nrcs.usda.gov/technical/eng/cad_support/ standard_dwgs/index.html U.S. Geological Survey's website for its water quantity and water quality data (NAWQA), both archival and real-time, surface and ground water. http://water.usgs.gov/nwis. U.S. Natural Resource Conservation Service. http://www.wa.nrcs.usda.gov/technical/eng. Good concept designs and other engineering support material.

x x

x x

x x

x x

Design information

Planning

x x

x x

x x

x x

x x

x

x

x

x

x

x

x

x

x

x x x

x x x

x x x

x x x

x x x

x x x

x x x

x x x

x x x

x x

x x

x x

x x

x x

x x

x x

x x

x x

Watershed Impact Assessment Guidance for Public Lands and Facilities

E-3

THIS PAGE INTENTIONALLY LEFT BLANK

E-4

Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix F Sample Forms
This appendix contains blank copies of Forms 1–5 which are presented in this report.

Watershed Impact Assessment Guidance for Public Lands and Facilities

F-1

Form 1. Summary of the Municipality’s Receiving Watersheds and Associated Waterbodies
Instructions: Complete this form for each 8-digit HUC watershed. Enter watershed priority scores (WPS) from Form 2. Please attach your watershed map to all Form 3s.

1. Name

2. State and County

3. Zip Code(s)

4. Name of 8-digit HUC watershed(s)

5. 8-digit HUC(s)

6. List of the Receiving Watersheds or Waterbodies Listed as Impaired by the Federal or State Regulators
Name of waterbody HUC, 8- to 16-digit, or state identifier List of impaired designated uses Summary of impairments of concern (from Form 2) WPS (from Form 2)

7. List of the Receiving Watersheds or Waterbodies Listed as Impaired by the Federal or State Regulators
HUC, 8- to 16-digit, or state identifier List of designated uses Summary of impairments of concern (from Form 2) WPS (from Form 2)

Name of waterbody

F-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Sample Forms

Form 2. Watershed Priority Score (WPS): A Sensitivity Scoring and Data Collection Form for Waterbodies/Watersheds
Complete a Form 2 for each waterbody listed Form 1. Record the WPS and pollutants of concern into Form 1 for each waterbody. 1. Name of the Watershed and Corresponding 8- to 16-Digit HUC Code (or State Identifier): 2. Waterbody/Watershed Impairment Score for the watershed listed in Block 1. Go to the State regulator or EPA’s State 305b reports to determine the waterbody’s designated uses and if they are being met. For each designated use, check the degree it meets the use, the impairment(s), and the causes/stressors.
Not Supporting = 3 pts Partially Supporting = 2pts Fully Supporting = 1pt Not a Designated Use= 0 pts

Designated Use a. Aquatic life use b. Fish consumption use c. Shell fishing use d. Swimming use e. Secondary contact use f. Drinking water use g. Agriculture use h. Cultural/ceremonial use i. State/municipal specific use _______________________

Impairment

Cause/Stressor

3. Transfer the State 303(d) listed pollutants of concern (impairments) from question 2 and note if the State has developed TMDL. a. 303(d) Impairment 1: b. 303(d) Impairment 2: c. 303(d) Impairment 3: d. 303(d) Impairment 4: e. 303(d) Impairment 5: 4. Waterbody/Watershed Vulnerability Score for the watershed listed in Block 1.

TMDL in place?
Yes = 3 pt No = 0 pts

Enter TMDL Effective Date

Yes = 1 pt

No = 0 pts

a. Are the impervious surfaces above 25% of watershed land area (for either current or projected land use)? b. Is the population growth rate of the watershed above 7%? c. Does waterbody contain impounded water (e.g., dams and fish barriers)? d. Is the receiving water listed as a protected estuary? 5. Has EPA, individual service, state, water authority, or local group listed restoration goals for the waterbody in Block 1? If so, list the specific goals. a. Biodiversity and habitat loss. If yes, list goal: b. Riparian buffer strip loss. If yes, list goal: c. Imperviousness/uncontrolled SW runoff. If yes, list goal: d. Invasive species. If yes, list goal: e. Wetlands. If yes, list goal: f. Other: If yes, list goal:
Yes = 1 pt No = 0 pts

6. Has an enforcement official requested the municipality to monitor/sample the waterbody? 7. Have water withdrawal/use restrictions been imposed for the waterbody? 8. Have potential impacts to human health been identified as a significant concern for the waterbody (e.g., air deposition of a pollutant to the waterbody, or pollutants in the water are causing a risk to drinking water)? 9. Is this watershed or waterbody designated as a special water resource under the American Heritage River Program, Great Lakes Program, Scenic Waters Program, or another special program?

10. Watershed Priority Score (WPS) = impairment score (blocks 2 a-i) + TMDLs (blocks 3 a-e) + vulnerability score (block 4 a-d) + goal score (blocks 5 a-f) + answers on blocks 6 to 9.

Watershed Impact Assessment Guidance for Public Lands and Facilities

F-3

Date Baseline Completed:

Activity ID #

Form 3. Summary List of Municipal Activities That Potentially Affect the Watershed

F-4
a. Contributes the following regulated impairments (e.g., TMDLs) 5. Compliance burden (e.g., governing laws, regulations, and required permits or plans) 6. Total Activity Burden Score (TABS=WPS+AIS) 7. Pollution prevention or enhancements possible? (Yes or No) 4. Potential activity watershed impact b. Contributes the following other impairments 1. Activity name 2. Activity location 3. Waterbody or subwatershed affected

Page ___ of ____

Watershed Impact Assessment Guidance for Public Lands and Facilities

Sample Forms

Form 4. Summary of Municipal Land Use Categories
Total # pervious acres Total # of Activities in each category (Refer to Form 3) Total acres in each category Acres covered by SWP3 or other plan (specify) Total % impervious Total # impervious acres Land use improvement goal (%)

Description of Land Use Categories Industrial: (Including: Facility Operations & Maintenance Areas, Motor Pools, Equipment & Material Storage Areas, Truck Parking, Wash Racks, Fueling Points, Industrial Treatment Plants, Fumigation Areas, or Shipping/Receiving Areas) Urban (Including: Commercial – Shopping Centers, Grocery Stores, Restaurants, Banks, Parking; Residential – Housing and Parking; Office Buildings and Parking; and roads) Mixed Use: (including gravel areas, low impact parking lots, total semimaintained open grounds (e.g., operational buffers and firebreaks), and recreational grounds (e.g., ball fields, horse stables, golf courses) Paved Roadways Construction Agricultural Operations Natural Areas Non-riparian forest Riparian forest and buffer strip Wetlands Grasslands or prairie Endangered species conservation areas Waterbodies (stream, pond, or other) Coastal area or estuary Other natural areas (e.g., beaches and deserts) Acres of natural areas slated as protected critical areas

Total for municipality:
Baseline conducted by: Date:

Watershed Impact Assessment Guidance for Public Lands and Facilities

F-5

% of goal accomplished

Total % pervious

Form 5. Summary Questions to Identify Key Physical Characteristics and Activities That May Potentially Impact the Watershed
Typical impacts or concerns with activity Unsure Number of activities (on-site)

Question about municipality characteristics or activities 1. Does the municipality contain streams or rivers that have visible signs of bank erosion, scouring, or unstable stream banks? If yes, note if caused by municipal or off-site activities. 2. Does the municipality contain streams or rivers that have barriers to fish spawning? If yes, note if caused by municipal or off-site activities. 3. Does the municipality contain areas that exhibit uncontrolled flooding during rain events? If yes, note if caused by municipal or off-site activities. 4. Does the municipality contain streams or rivers without adequate riparian buffer (as defined by watershed goals or local zoning requirements)? 5. Does the municipality contain steep slopes or other areas that exhibit visible signs of erosion? If yes, note if caused by municipal or off-site activities. 6. Does the municipality contain impervious areas (roads, parking lots, buildings, etc.) that drain directly to receiving waters without retention or detention controls? 7. Do any upstream properties or activities drain onto the municipality that may affect water quality or cause on site flooding or stream scouring?

Yes

No

Comments

Aquatic habitat degradation, sedimentation, and flooding

Aquatic habitat degradation, sedimentation, and flooding Aquatic habitat degradation, sedimentation, and flooding Aquatic habitat degradation and sedimentation

Sedimentation and flooding

Flooding and aquatic habitat degradation

Flooding, toxic or conventional pollutants, TMDLs, and aquatic habitat degradation Toxic or conventional pollutants to aquifers and TMDLs

8. Does the municipality contain septic systems or other underground injection wells?

Note: For each question answered yes or unsure, list a specific activity or area on Form 3. For each activity listed on Form 3, complete a Form 6.

F-6

Watershed Impact Assessment Guidance for Public Lands and Facilities

Sample Forms

Form 5. Summary Questions to Identify Key Physical Characteristics and Activities That May Potentially Impact the Watershed (Continued)
Typical impacts or concerns with activity
Regulatory burden such as source water protection, wellhead protection, or conservation plans Toxic or conventional pollutants, TMDLs, sedimentation, spills, and regulatory burden (e.g., plans) Spills to surface or ground waters and regulatory burden Toxic pollutants, TMDLs, spills, and regulatory burden Toxic or conventional pollutants, TMDLs, spills, and regulatory burden Toxic or conventional pollutants, TMDLs, spills, and regulatory burden Sedimentation and regulatory burden

Unsure

Question about municipal characteristics or activities

Number of activities (on-site)

Yes

No

Comments

9.

Does the municipality produce its own drinking water? If yes, note if using ground or surface waters

10. Does the municipality conduct industrial activities that require NPDES wastewater, pretreatment, or storm water discharge permit?

11. Does the municipality maintain bulk storage of POLs or EPRCA chemicals in USTs or ASTs? 12. Does the municipality conduct fleet fueling operations or operate fueling stations? 13. Does the municipality have uncovered bulk storage of industrial chemicals, materials, wastes, or equipment (e.g., salt or coal piles)? 14. Does the municipality apply fertilizers or pesticides on its property? 15. Is the municipality undertaking or planning major construction or ground disturbing activities?

Note: For each question answered yes or unsure, list a specific activity or area on Form 3. For each activity listed on Form 3, complete a Form 6.

Watershed Impact Assessment Guidance for Public Lands and Facilities

F-7

THIS PAGE INTENTIONALLY LEFT BLANK

F-8

Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix G Sample Project Sheet Format
While it is important to document each activity’s affects to the watershed conditions, having the project information in separate locations makes it difficult to summarize the work plan efforts or to identify opportunities for coordinating watershed management efforts. Thus, this Appendix contains the following recommended format for summary information, which users can use to enter their activity impact and project information for different management purposes such as prioritizing budget requests and tracking project implementation progress and results.

Watershed Impact Assessment Guidance for Public Lands and Facilities

G-1

THIS PAGE INTENTIONALLY LEFT BLANK

G-2

Watershed Impact Assessment Guidance for Public Lands and Facilities

Sample Project Sheet Format

Project Title
Activity/Site Name
Project Priority:

Site Photo

Location: (latitude and longitude, building number, or description)

Problem Description Proposed Project Objective and Benefits
Proposed Project Concept Design
Design Concept Maintenance Requirements Permits and Legal Requirements

Proposed Funding Sources
FUNDING PROPOSAL
Project Title Budget Justification Other Potential Funding Sources

Proposed Budget and Schedule
Cost Schedule Cost Benefit Data

Potential Partners/Stakeholders
Responsible Municipal Office Other Partners

Additional References
Technical Documents POCs at other locations that have implemented similar projects

Watershed Impact Assessment Guidance for Public Lands and Facilities

G-3

THIS PAGE INTENTIONALLY LEFT BLANK

G-4

Watershed Impact Assessment Guidance for Public Lands and Facilities