Skip to main content


The full text article is not available for purchase.

The publisher only permits individual articles to be downloaded by subscribers.

or click here to sign up for a free trial


According to the United States Environmental Protection Agency (USEPA), watershedbased NPDES permitting is an approach to developing NPDES permits for multiple point sources located within a defined geographic area (i.e., watershed boundaries) (USEPA, 2003). In establishing point source controls in a watershed-based permit, the permitting authority may focus on watershed goals, and consider multiple pollutant sources and stressors, including the level of nonpoint source control that is practicable. Sanitation District No. 1 of Northern Kentucky (District) has secured funding from USEPA through a cooperative agreement to develop an approach for watershed-based permitting (Clean Water Act Section 104(b)(3)). The District is responsible for the collection and treatment of Northern Kentucky's wastewater, as well as regional storm water management. The District serves 33 communities in Boone, Campbell, and Kenton Counties of Northern Kentucky.

The watershed-based permitting approach discussed in this paper takes advantage of the regional extent of the District's service area, as well as an extensive database of water quality and GIS information that the District has compiled for their service area. It is expected that a single permit would be issued for discharges under the District's control within a watershed, in lieu of the KPDES permits currently issued to the District, such as those related to stormwater and sanitary sewer issues, including CSOs.

The watershed permit being explored would prescribe an approach toward controlling all watershed sources of pollution, and prioritizing and selecting controls. The approach is based entirely on the concept of adaptive watershed management, which is a means to ensure attainment of water quality standards in a cost-effective and timely manner. This approach is focused on doing better science, which will lead to more effective decisions and faster progress in improving water quality.

It is generally not possible to accurately specify individual controls or numeric limits at the onset of the permitting process because information on water quality conditions and stressors is incomplete. The permit instead would require adherence to a detailed adaptive watershed management process, which requires continual steps of controls and monitoring with progress towards attaining water quality standards while maximizing the efficiency of pollution control efforts. This progress would be ensured through development of a detailed and enforceable implementation plan for improving water quality.

To date, an approach to watershed-based permitting has been developed and this approach has been discussed with both the Kentucky Division of Water and the USEPA. A feasibility assessment concluded that this watershed-based permitting approach provides a significant improvement over the existing, traditional NPDES permitting approach and the District and the Kentucky Division of Water have agreed to pursue additional dialog on the development of a draft watershed permit for Banklick Creek, focusing on wet weather discharges. This watershed was selected because it is impacted by urban storm water runoff, sanitary sewer overflows, septic systems and rural runoff. The District's waste water treatment plant does not discharge into the Banklick Creek watershed.

Document Type: Research Article


Publication date: January 1, 2004

More about this publication?
  • Proceedings of the Water Environment Federation is an archive of papers published in the proceedings of the annual Water Environment Federation® Technical Exhibition and Conference (WEFTEC® ) and specialty conferences held since the year 2000. These proceedings are not peer reviewed.

    WEF Members: Sign in (right panel) with your IngentaConnect user name and password to receive complimentary access.
  • Subscribe to this Title
  • Membership Information
  • About WEF Proceedings
  • WEFTEC Conference Information
  • Ingenta Connect is not responsible for the content or availability of external websites

Access Key

Free Content
Free content
New Content
New content
Open Access Content
Open access content
Partial Open Access Content
Partial Open access content
Subscribed Content
Subscribed content
Free Trial Content
Free trial content
Cookie Policy
Cookie Policy
Ingenta Connect website makes use of cookies so as to keep track of data that you have filled in. I am Happy with this Find out more