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COUNTY WATER QUALITY ISSUE BRIEF National Association of Counties | Community Services Total Maximum Daily Loads (TMDLs) A Watershed Planning Tool for Counties
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COUNTYWATERQUALITYISSUEBRIEF

National Association of Counties | Community Services

TotalMaximumDailyLoads(TMDLs)AWatershedPlanningToolforCounties

About the National Association of Counties

Founded in 1935, the National Association of Counties (NACo) is the only national organization representing county governments in the nation’s capital. With headquarters on Capitol Hill in Washington, D.C., NACo’s primary mission is to ensure that the county government message is heard and understood in the White House and the halls of Congress. NACo’s purpose and objectives are to:

• Serve as a liaison with other levels of government;• Improve public understanding of counties;• Act as a national advocate for counties; and• Help counties find innovative methods for meeting the challenges they face.

For more information about NACo or to request copies of this publication, please contact:

Erik JohnstonCommunity Services AssistantPhone: 202.942.4246Email: [email protected]

This issue brief was published in August 2006 and made possible through support from U.S. Environmental Protection Agency (USEPA) Cooperative Assistance Agreement # CD - 83266201. It was written by Erik Johnston, NACo Community Services Assistant with technical contributions by Sarah Furtak, USEPA and edited by Abby Friedman, NACo Program Director. Graphic design and layout was performed by Sonia Chu of NACo. Photographs were provided by Doug Norton, USEPA; Jim Harris, Polly Johnson, Clallam County Environmental Health Division, Stephen McCracken and Texas Parks and Wildlife Department. The opinions in this publication are those of the contributors, and do not necessarily reflect the views of the USEPA or NACo.

Acknowledgements:

NACo wishes to thank the following individuals for their time and contributions to the development of this publication:

• Sarah Furtak, Assessment and Watershed Protection Division, U.S. Environmental Protection Agency• Rebecca Dils, Project Officer, Wetlands Division, U.S. Environmental Protection Agency• Eric Monschein, Assessment and Watershed Protection Division, U.S. Environmental Protection Agency• Andy Brastad, Janine Reed, and Elizabeth Maier, Clallam County (Washington) Environmental Health Division• Polly Johnson, Watershed Coordinator, Sanpete County Soil Conservation District • Claudia Jarrett, Commissioner, Sanpete County, Utah• Jon Steffen, Principle Engineer Stormwater Management Division, DuPage County, Illinois• Stephen McCracken, Director of Watershed Protection, The Conservation Foundation

COUNTYWATERQUALITY

ISSUEBRIEF

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IntroductionAs both rural and urban populations continue to grow, counties are challenged with protecting drinking water supplies, providing citizens with effective sewage and water infrastructure, restoring wetlands, and managing water in situations of drought. Watershed planning plays a critical role in county efforts to meet challenges to water quality.

KeyTermsAntidegradation - A policy designed to prevent de-terioration of existing levels of good water quality.

Background Source – Source or load of a pollutant in question that is (1) human-caused, coming from upstream or (2) already present and naturally-occur-ring (not human-caused).

Designated Uses - Uses that society, through states and the federal government, determines should be attained in the waterbody. Examples include warm water aquatic ecosystems, public water supply, and recreational fishing.

Impaired Water – Water that is not meeting water quality standards.

303 (d) Listed Stream - A stream that is included on a state’s list of impaired waters, or a polluted stream, based on not meeting water quality standards set by the state. TMDLs are created for such streams.

Load – Amount of pollutant in a water body.

Key terms found throughout the issue brief are in bold face text. The definitions of these terms are found in the Key Terms section.

The U.S. EPA is increasingly working with states and local governments to improve water quality protection tools. One of the most prominent tools that counties across the nation have encountered or will encounter in the future is the U.S. EPA’s Total Maximum Daily Load Program or TMDL Program. This tool is a calculation utilized in most efforts to restore polluted waters. Total Maximum Daily Loads (TMDLs) have been the impetus for many county-led or supported water quality improvement success stories. However, there have also been a few lawsuits filed against specific TMDLs and some confusion about the program at the local level. This issue brief is designed to provide county staff and officials with information to help them navigate the TMDL process.

Nonpoint Source (NPS) Pollution - Pollution that, unlike pollution from industrial and sewage treat-ment plants, comes from many diffuse sources. NPS pollution is caused by rainfall or snowmelt moving over and through the ground. As the runoff moves, it picks up and carries away natural and manmade pollutants, finally depositing them into lakes, rivers, wetlands, coastal waters, and even our underground sources of drinking water. Examples of these non-point source pollutants may be residential fertilizer or insecticides and oil and grease from roadways.

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Point Source Pollution – Pollution carried by discrete conveyances, such as pipes or man-made ditches. This includes not only discharges from municipal sewage plants and industrial facilities, but also collected storm drainage from larger urban areas, certain animal feedlots and fish farms, some types of ships, tank trucks, offshore oil platforms, and collected runoff from many construction sites.

Section 319 – Section 319 of the Clean Water Act contains the EPA’s Nonpoint Source Management Program. Under section 319, states, territories, and tribes receive grant money and often pass the fund-ing along to counties and other local groups to sup-port a wide variety of activities including technical assistance, financial assistance, education, training, technology transfer, demonstration projects, and monitoring to assess the success of specific non-point source implementation projects.

NPDES Stormwater Phase 1 permits – Refers to the EPA’s National Pollutant Discharge Elimination System (NPDES) program established through the Clean Water Act. Phase I of the NPDES stormwater program requires permit coverage for large or medi-um municipalities that have populations of 100,000 or more. Phase II builds upon the Phase I program by requiring smaller communities and public entities that own and operate a Municipal Separate Storm Sewer System to apply and obtain an NPDES permit for stormwater discharges.

Water Quality Standards – Define goals set by states and tribes for a water body. They identify the designated uses, water quality criteria, and antideg-radation provisions for bodies of water.

WhatareTotalMaximumDailyLoads(TMDLs)?A Total Maximum Daily Load (TMDL) is “a pollutant diet” or a calculation of the maximum amount of a pollutant that a waterbody can receive and still meet water quality standards set by a state or tribe, and an allocation of that amount to the pollutant’s point and nonpoint sources. The calculation must include a margin of safety to ensure that the waterbody can be utilized for its designated uses set by the state or tribe.

WhatistheTMDLProgram?Section 303 of the Clean Water Act establishes water quality standards (303(c)) and EPA’s TMDL Program (303(d)). The Act first requires states to: 1. Develop lists of impaired waters (defined) needing TMDLs every two years (2002, 2004, 2006…) 2. Establish TMDLs for these impaired waters. EPA must review these lists or TMDLs and either approve them or establish replacement lists or TMDLs.

WhyareTMDLsSoCommon?While TMDLs have been required by the Clean Water Act since 1972, by the mid-90s, few TMDLs had been established. At that point, citizen organizations began bringing legal actions against EPA seeking the listing of waters and development of TMDLs. To date, there have been about 40 legal actions in 38 states. Currently, EPA is under court order or has agreed in consent decrees to ensure that TMDLs are established in 22 states, either by the state or by EPA. To view a list of these 22 states and for more information about TMDL litigation visit www.epa.gov/owow/tmdl/lawsuit1.html.

Thisissuebriefwillfocuson:

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1. Adopt Water Quality Standards

2. Monitor & Assess Waters

3. List Impaired Waters

4. Develop TMDLs

5. Implement TMDLsCounties and their partners can participate in implementation. Counties should seek a broad range of partners and apply for EPA and state grant funding.

Participate in TMDL development and/or develop TMDLs locally. Early involvement has more impact on outcomes and third party development gives more control to counties.

Comment on list of impaired waters.

Collect and submit county monitoring data to the state to ensure local level accuracy.

Comment on proposed water quality standards. Counties can offer ideas to the state on what the state should adopt for waters in the county.

Clean Water Act Process How Counties Can Get Involved

Framework for Restoring Polluted Waters

Now, many stakeholders recognize that TMDLs are an important tool for protecting and restoring water quality (see case studies in later pages).

WhyShouldCountiesCareAboutTMDLs?States are not required to specifically consult counties when they develop their lists of impaired waters. Counties and other local stakeholders may be held responsible to implement portions of the TMDL action plans and accept the creation of TMDLs. Counties that get involved early and often are more likely to help their state and EPA develop water quality criteria and implementation plans that are tailored to local conditions. In addition, the TMDL process offers counties a vehicle to improve their local water quality.

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Note: As shown in the chart and discussed in this issue brief, TMDLs are part of a framework for restoring polluted waters.

1. States, territories, and authorized tribes establish water quality standards per Clean Water Act section 303(c). EPA reviews and approves these standards.

2. Sections 305(b) and 303(d) require that states, territories, and authorized tribes provide EPA biennial reports which include (1) summaries of the condition of waters within their boundaries and;

3. (2) lists of impaired waters (i.e., waters not meeting standards) needing TMDLs within their boundaries.

4. TMDLs are developed for these impaired waters.

Both regulatory [e.g., National Pollutant Discharge Elimination System permits under section 303(e)] and voluntary controls (e.g., nonpoint source best management practices under section 319, such as planting trees along stream banks) help turn written TMDLs into action to restore water bodies.

TMDLProgramBenefitsforCounties:

State Agencies typically develop TMDLs. Counties that engage in

the TMDL creation process can work to ensure that their voice is heard in the process and that local data and knowledge are incorporated.

TIP:

WhoDevelopsandApprovesTMDLsA. The Clean Water Act places the responsibility for developing TMDLs on the states. The states then must submit the TMDLs to EPA for approval.

B. EPA establishes TMDLs when a state is not developing TMDLs at a pace sufficient for EPA to meet its legal obligations established by court order or consent decree.

C. Third parties can work with their state agency and EPA to develop TMDLs. Counties or their partners are often involved in this process, typically through a stakeholder coordinating group. This opportunity for involvement helps counties ensure that the approaches and science used to develop the TMDL are consistent with their local knowledge of the situation.

Lakes

Estuaries

Streams/Rivers

Top Five Pollutants Responsible for 303(d) Listing

(by waterbody type)

Based on 2002 303(d) listing cycle

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A strength of the TMDL Program is its ability to support development of information-based, water quality management strategies. If done properly, a TMDL “can inform, empower, and energize citizens, local communities, and States to improve water quality at the local, watershed level. The basic information derived from a sound TMDL could liberate the creative energies of those most likely to benefit from reduced pollutant loadings to their own waters”

- G. Tracy Mehan IIIFormer Assistant Administrator of the Office of Water

November 2001

Metals 9090

Sediment/Siltation 5020

Pathogens 4868

Fish Consumption Advisory 3177

Organic Enrichment/Low Dissolved Oxygen 3075

Biological Criteria 2091

Thermal Modifications 2088

Nutrients 1408

Other Habitat Alterations 1310

Pesticides 799

Flow Alteration 734

Salinity/Total Dissolved Solids/Chlorides 726

Unionized Ammonia 709

Cause Unknown 517

PCBS 508

Top 15 Causes of 303(d) listing (all waterbodies)

93% of impairments included. Metals come from blanket state listings for Mercury in lakes.Based on 2002 303(d) listing cycle

The TMDL Program is commonly misunderstood as an unfunded

mandate. However, grant funding is available from EPA and often passed through state agencies to partially fund implementation plans.

TIP:

TheNeed-TheQualityofOurNation’sWatersAccording to the EPA, over 40% of our assessed waters still do not meet the water quality standards that states, territories, and tribes have set for them. This amounts to over 20,000 individual river segments, lakes, and estuaries. These impaired waters include about 300,000 miles of rivers and shorelines and approximately 5 million acres of lakes -- polluted mostly by sediments, excess nutrients, and harmful microorganisms. An overwhelming majority of the population - 218 million - live within 10 miles of these impaired waters.

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The group began to identify bacterial sources such as failing septic systems, poorly maintained livestock, pet waste, and other pollutants and proactively began to work on correcting these sources of bacterial waste. The strong level of partnership and proactive energy convinced federal and state funders to invest heavily in the group’s TMDL implementation plan. Since 2000, the state has allocated approximately $1.5 million, for monitoring and TMDL-related projects, $73,000 of which was section 319 funding from the EPA. The Jamestown S’Klallam Tribe also received $250,000 in section 319 funding and an almost $1 million EPA Targeted Watershed Grant to implement the plan.

The county’s role in the implementation plan is primarily focused on monitoring and septic system maintenance education. The Clallam County Environmental Health Division has one paid staff member financed through the Targeted Watershed Grant who works full time to offer education and financial incentives to landowners with failing septic systems located in the watershed. The county conducts site visits and Septics 101, a basic septic maintenance clinic, which has reached over 1,500 septic owners.

The county and its partners’ hard work has led to considerable improvement in water quality. All monitoring sites within Matriotti Creek are improving and some sites now meet bacteria target levels. The Clean Water Action Group hopes to

ClallamCounty,Washington:ReducingBacterialWasteThis coastal county of 64,000 people is located in the northern half of Washington State’s Olympic Peninsula. The Washington Department of Ecology added the county’s Dungeness River and Matriotti Creek (a tributary of the Dungeness River) to its 303(d) list of impaired waters in 1996 due to high levels of bacteria in the water. The county began to develop partnerships to address this issue, but no “smoking gun” was found. However, by 2003 over 500 acres of the economically important Dungeness Bay were closed to commercial and recreational shellfish harvesting due to unsafe fecal coliform bacteria levels.

By 2004 the EPA had approved fecal coliform TMDLs for Dungeness River, Matriotti Creek and the Dungeness Bay. The fecal coliform levels were of serious concern to Clallam County and its partner the Jamestown S’Klallam Tribe because of its impact on public health, the region’s vital tourism industry, and the decimation of shellfish harvesting.

Clallam County commissioners knew they faced a daunting water quality issue, but lacked the capacity to solve the problem alone. Due to the closure of the commercial shellfish areas they were required to establish a shellfish protection district and in doing so expanded the informal partnerships developed in 1996, which by 2001 became the formalized Clean Water Work Group. The work group includes Clallam County, Jamestown S’Klallam Tribe, Clallam Conservation District, Sequim-Dungeness Water Users, Dungeness River Management Team, Washington State Department of Health, Battelle (a private lab), U.S. Fish and Wildlife Service, Puget Sound Action Team, City of Sequim, and the Washington State Department of Ecology.

Clallam County, Washington residents participate in Septics 101. This class is designed improve water quality by teach-ing county residents proper septic system maintenance.

There is grant funding available for TMDL implementation plans.

Strong partnership with your state agency, EPA, and other local partners will increase your county’s chances of obtaining funding to implement your TMDL. See resources section for more information.

TIP:

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achieve bacterial reduction for the TMDLs in the Dungeness River and Matriotti Creek by 2007.

According to Andy Brastad, Clallam County Environmental Health Manager, the county views TMDLs as a water quality tool and not a punishment handed down by the state and EPA. Brastad emphasized that “our staff has been involved from the very beginning of this issue. Early involvement and partnership building has been a key to our success. We are addressing the TMDL issue, saved money by sharing resources, and increased our capacity to address water quality issues of critical importance to our county and state.”

The San Pitch River is one critical source of water that is located almost entirely within the county. Since 1998, the river has been on Utah’s 303(d) list because of too many Total Dissolved Solids (TDS). Water with high levels of dissolved solids contains abnormal amounts of minerals that decrease water quality. High salt content is the major TDS pollutant in the San Pitch River, but sediment and phosphorous are also TDS issues. High salinity levels are bad for wildlife, contaminate well water, and can significantly reduce the productivity of agricultural land.

Wetland loss, population growth, agricultural runoff, and stormwater runoff all played a role in contributing to the high TDS levels. The county and its partners such as the Sanpete Soil Conservation District and Farm Bureau formed the San Pitch River Watershed Stewardship Group to confront

For more information, visit www.epa.gov/owow/nps/Success319/state/wa_dungeness.htm, or www.clallam.net/EnvHealth/html/sf_downgrade.htm.

SanpeteCounty,Utah:RestoringtheSanPitchRiverandAgricultureSanpete County is a rural county of around 23,000 people located 90 miles south of Salt Lake City. Agriculture is the dominant economic sector with nearly 800 farms in the county comprising about 25% of the total land area. The county’s semi-arid climate coupled with its economic dependence on irrigation and animal feeding operations make water quality and quantity especially vital to the county’s economic health.

A photo of a San Pitch River restoration project in progress.

“Our staff has been involved from the very beginning of this issue. Early involvement and partnership building has been a key to our success. We are addressing the TMDL issue, saved money by sharing resources, and increased our capacity to address water quality issues of critical importance to our county and state.”

Andy BrastadEnvironmental Health Manager

Clallam County, Washington

An example of erosion along a river. Eroded banks along riv-ers and streams contribute to decreased water quality.

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these diffuse nonpoint sources of pollution. Sanpete County Commissioner Claudia Jarrett serves on the workgroup and praised the joint effort. “The 303(d) listing spurred our community into more formalized actions to improve water quality. The stewardship group’s plan to improve water quality will benefit all of our county’s residents and wildlife. This is a true win-win initiative,” said Jarrett.

The partnership successfully created a Water Quality Management Plan for the river with twelve actions designed to encourage Sanpete landowners and farmers to take steps to increase riparian wetland buffers and decrease agricultural and stormwater runoff.

DuPageCounty,Illinois:SavingMoneyThroughCollaborationDuPage County is a large suburban county of over 900,000 people located to the immediate west of Chicago. The county historically worked with its municipalities to improve water quality through a countywide nonpoint source pollution education plan and other programs. Despite these efforts, water quality problems persisted and the state issued multiple TMDLs for Salt Creek and the East and West Branch of the DuPage River. The TMDLs included conductivity, chloride, copper, dissolved oxygen, and phosphorus. The initial TMDL report recommended, for the most part, tighter control of Stormwater Phase 1 permits with each county wastewater treatment plant potentially responsible for tens of millions of dollars in upgrades.

“The 303(d) listing spurred our community into more formalized actions to improve water quality. The stewardship group’s plan to improve water quality will benefit all of our county’s residents and wildlife. This is a true win-win initiative.”

Claudia Jarrett Sanpete County, Utah Commissioner

Doug Scott, Director of the Illinois Environmental Protection Agency presents the DuPage River Salt Creek Workgroup with funding for a TMDL implementation plan.

Teachers in Sanpete County, Utah learn about their water-shed during a training session conducted by the conserva-tion district.

For more information, contact Polly Johnson, Sanpete County Soil Conservation District at 435-835-4113 or visit www.sanpetemessenger.com/news3-15-06_1.html.

The county, environmental groups, municipalities and wastewater treatment plants all came together to tackle water quality issues in the three waterbodies. These stakeholders organized to form the DuPage River Salt Creek Workgroup. This broad, yet cohesive coalition convinced the Illinois Environmental Protection Agency that such investments were unlikely to obtain the desired water quality goals, but that other watershed planning based initiatives could. The new approach has the potential to save millions of dollars in expenses on projects that do not guarantee water quality improvement. The Workgroup is now chartered and working on an implementation plan. All group members pay dues that help provide the necessary match for the $600,000 in section 319 funding they have received to implement the plan.

For more information, visit www.DRSCW.org

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HowtoCalculateaTMDLA TMDL is made up of the sum of all the point source loads (amounts of pollutants) or waste load allocation (WLA) and loads associated with nonpoint sources and background sources (load allocation or LA).

TMDLs must include a margin of safety (MOS) explicitly or implicitly and consider seasonal variations.

TMDL Formula:

WLA + LA + MOS = TMDLThe TMDL equation follows:

WLA = Waste Load Allocation - (Amount of pollutant from existing/future point sources)LA = Load Allocation - (Nonpoint source and natural background loads)MOS = Margin of Safety- (Part of the TMDL is allocated to the MOS to account for the lack of certainty regarding how the water will respond to changes in loadings.)

Appendix

ExampleTMDLCalculation:

Determine the loading capacity (the quantity of pollutant that a water body can receive without causing or contributing to a violation of water quality standards).

The loading capacity for each pollutant [e.g., the pesticide chlordane, expressed in pounds per day (lbs/day)] is based on: Criteria [in micrograms per liter (µg/l)]; multiplied by Receiving water flow [cubic feet per second (cfs)] and a Conversion factor [to convert (µg/l) and (cfs) into lbs/day].

For example: Loading capacity = (criteria) (water flow) (conversion factor)

= (0.0005 µg/l) (1,113 cfs) (0.00539)= 0.00299 lbs/day ≈ 0.003 lbs/day

Divide the loading capacity into allocations for nonpoint sources and point sources after taking into account background loadings and the MOS (in this example, 10% of the loading capacity).

In this example, MOS = (Loading Capacity) (MOS percent) MOS = (0.003 lbs/day) (0.1) MOS ≈ 0.0003 lbs/day

The calculations can be incorporated into the TMDL equation as follows:

WLA + LA + MOS = TMDL 0 + 0.0027 lbs/day + 0.0003 lbs/day = TMDL (Note: WLA equals zero because there is no point source of this pesticide – it is a nonpoint source pollutant)

TMDL ≈ 0.003 lbs/day

For more information on TMDLs, including more detailed calculations, please see EPA’s TMDL homepage at www.epa.gov/owow/tmdl. Detailed TMDL calculations are available at EPA’s “Examples of Approved TMDLs” Web site at www.epa.gov/owow/tmdl/examples/.

Step 1:

Step 2:

Step 3:

LA = Loading Capacity – MOSLA = 0.003 lbs/day - 0.0003 lbs/dayLA ≈ 0.0027 lbs/day

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ResourcesforLocalGovernments National Association of Counties (NACo)

– Provides county officials with wetlands and watershed technical and legislative assistance as well as funding through the Five Star Restoration Challenge Grant Program and Coastal Counties Restoration Initiative. www.naco.org/techassistance under “Water Quality” or contact Erik Johnston at (202) 942-4246 or [email protected].

U.S. Environmental Protection Agency (EPA) – Provides comprehensive information on TMDL regulations, financial assistance, and regional resources. www.epa.gov/owow/tmdl/

- For information about section 319 grant funding EPA has compiled a list of state contacts. Counties should contact their state Nonpoint Source Pollution Program Coordinator. The most up to date list of state coordinators is available at www.epa.gov/owow/nps/319hfunds.html

- For information about EPA’s Targeted Watershed Grants go to www.epa.gov/owow/watershed/initiative/

- EPA’s Watershed Funding Web site is an excellent comprehensive guide to funding sources. Go to www.epa.gov/owow/funding.html

- EPA’s Watersheds Home Page, www.epa.gov/owow/watershed/

- EPA’s Wetlands Division, www.epa.gov/owow/wetlands/

- The ABCs of TMDLs for Stakeholders Webcast, www.epa.gov/owow/watershed/wacademy/webcasts/

- For more details on impaired water lists, TMDLs, and related Clean Water Act requirements, please see the Guidance for 2006 Assessment, Listing, and Reporting Requirements Pursuant to Sections 303(d), 305(b), and 314 of the Clean Water Act (with accompanying fact sheets) at www.epa.gov/owow/tmdl/2006IRG/ and “New Policies for Establishing and Implementing TMDLs” at www.epa.gov/OWOW/tmdl/ratepace1997guid.pdf

Center for Watershed Protection – Provides education, outreach and training on watershed protection, planning, restoration and research as well as stormwater management and better site design. www.cwp.org

TMDLS.NET - This site was created as a joint effort of America’s Clean Water Foundation and the Association of State and Interstate Water Pollution Control Administrators to convey important information relating to TMDLs. The site contains numerous TMDL examples by type and pollutant along with other technical assistance information. www.tmdls.net

References:Hales, John and Sue Gillham. (2006, March 15). Plan Seeks to Improve Quality of San Pitch. San Pete Messenger. www.sanpetemessenger.com/news3-15-06_1.html.

Monschein, Eric. (2005, July 16). Total Maximum Daily Loads (TMDLs): A Watershed Planning Tool for Counties. PowerPoint presentation delivered at NACo’s 2005 Annual Conference.

San Pitch River Watershed Stewardship Group. (2006, January). San Pitch River Watershed: Water Quality Management Plan.

U.S. Environmental Protection Agency. (2006). EPA’s TMDL Web site. www.epa.gov/owow/tmdl/.

U.S. Environmental Protection Agency Region 9. (2000, January 7). Guidance for Developing TMDLs in California. www.epa.gov/region9/water/tmdl/303d-2002pdfs/caguidefinal.pdf.

U.S. Environmental Protection Agency. (2005, October). Section 319 Source Program Success Story: Washington and Jamestown S’Klallam Tribe. www.epa.gov/nps/Success319/state/wa_dungeness.htm.

U.S. Environmental Protection Agency. (2001, No-vember 15). Testimony of G. Tracy Mehan, III, As-sistant Administrator for Water, U.S. Enivironmental Protection Agency, Before the Subcommittee on Water Resources and Environment of the Committee on Transportation and Infrastructure, U.S. House of Representatives. www.epa.gov/water/speeches/111501tmdls.pdf

U.S. Environmental Protection Agency. (1994). What is Nonpoint Source Pollution? Questions and Answers. www.epa.gov/owow/nps/qa.html.

U.S. Environmental Protection Agency. (2006). Water Quality Standards: Basic Information. www.epa.gov/waterscience/standards/about/.

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440 First Street NW • Washington DC 20001• www.naco.org

COUNTYWATERQUALITY

ISSUEBRIEF


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