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Implementing a National Pollutant Discharge Elimination System (NPDES) Watershed-Based Permitting Approach for Nutrients

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The views presented in this paper are solely those of the authors and do not reflect the official views of the U.S. Environmental Protection Agency.

In December 2003, the U.S. Environmental Protection Agency (EPA) published its Watershed-Based National Pollutant Discharge Elimination System (NPDES) Permitting Implementation Guidance [EPA 833-B-03-004] and followed up with the Watershed-Based National Pollutant Discharge Elimination System (NPDES) Permitting Technical Guidance [EPA 833-B-07-004] in August 2007. These guidance documents consider a process for integrating the NPDES permitting program into a larger watershed management approach and coordinating NPDES activities with other water quality activities in the watershed. They describe a process of data collection and analysis conducted to support the development and issuance of NPDES permits that consider the diverse pollutant sources and stressors located within a defined geographic area (i.e., watershed boundaries). The conclusions reached through this watershed-based analytical approach lead to a broad range of possible NPDES or other program implementation options to achieve watershed goals. These options might extend beyond the traditional approach of developing and issuing a single NPDES permit to an individual point source discharger. The specific options and tools selected for the resulting NPDES watershed framework will depend on the characteristics of the watershed, the pollutants of concern, the sources of those pollutants, and the permitting context. One such tool is a watershed-based permit. Several permitting authorities have developed or considered a type of watershed-based permit, a multisource watershed-based permit, to address nutrient discharges within one or more watershed.

This paper and presentation review the concepts of a watershed permitting analytical approach and an NPDES watershed framework as presented in EPA guidance, and focuses on the option of issuing a multisource watershed-based NPDES permit. Specifically, the presentation focuses on three case studies that illustrate how permitting authorities have analyzed particular watersheds, developed a watershed framework, and developed and issued multisource watershed-based permits for nutrients.

Keywords: Chesapeake Bay; Long Island Sound; National Pollutant Discharge Elimination System (NPDES); Neuse River Estuary; Nutrients; Permit; Watershed

Document Type: Research Article


Publication date: January 1, 2009

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