Summary: Ad Hoc Watershed Scale Planning topics, watershed topic ideas, permit comments
Please send feedback to:
Danielle Shaw: Washington Environmental Council [email protected]
2018 Stormwater Permit Subgroup: Watershed Planning
Guiding Principles
Current Permit Feedback
The current Phase I watershed planning requirement is too prescriptive in its approach to be applied more
broadly. A better balance needs to be struck between prescription and flexibility.
Current language in the first paragraph presupposes stormwater is the primary cause of harm to existing
and designated uses. Recommendation to change language in first paragraph of permit requirement from
“result in†to “fully support,†then add the language of “that contribute to.â€
The price tag and resource commitment required under the current Phase I watershed planning
requirement has proven a heavy lift and would be overly burdensome on smaller Phase II jurisdictions as
well as an unsustainable path for Phase I jurisdictions to continue to pursue.
The current modeling results are not generating transferrable knowledge to build the case that high initial
expenditures can produce payoffs by helping reduce the price tag for other watershed plans.
Some of the prescriptive requirements do not translate well across jurisdictions or watersheds. For
example, B-IBI data is not always an appropriate biological assessment tool for certain types of
waterbodies.
Additionally, current prescriptive requirements are not beneficial for generating output to help inform
flood control programs and other basin planning efforts, potentially proving counterproductive as
resources are driven from those efforts towards this resource-intensive requirement.
Implementation, evaluation, and adaptive management were neglected in this permit requirement.
Guiding Principles for 2018 Watershed Planning Requirements
1. Regulatory Purpose
The purpose of the watershed planning requirement is the protection and restoration of the
beneficial uses of our water bodies.
To meet this purpose, the requirement should generate a planning tool to guide and target
capital actions (e.g., retrofits, facility improvements, restoration) and programmatic efforts (e.g.,
education and outreach, O&M, source control, land use planning, etc.) that support stormwater
management efforts to achieve clean water and ecological function goals.
This purpose is environmental. This planning tool should focus on stormwater, recognizing that
the impairments are likely tied to a broader set of pressures/sources.
2. Outcome-Based Requirement
The requirement should be reframed by its intended outcome: guide stormwater management
investment and programs that contribute to healthy waterways.
The discrete outcome could be a generating a list of prioritized actions and/or targeted programs
necessary to contribute in achieving clean water goals within a 5-year permit cycle. One example
of a discrete outcome could be a certain number of stormwater retrofit projects.
3. Increased Flexibility
An outcome-based requirement could allow more flexibility in the approach to achieve the
prescribed outcome.
The diversity of watersheds and jurisdictional capacity and resources should lend to a more
flexible and effective watershed planning requirement than what the current Phase I permit
language allows.
The scale of the planning effort needs to be flexible as well. Some might be multi-jurisdictional
and large in scale, others might be small and within one jurisdiction. The permit should not
predetermine an acceptable size. Though cross-jurisdictional collaboration should continue to be
supported when the watershed prioritized crosses jurisdictional boundaries.
To that same point, the way watershed sizing has been described in current Phase I requirements
should not be applied to Phase IIs. Smaller jurisdictions may only be able to manage their
watershed as a microcosm within a greater watershed.
A watershed plan should (1) prioritize a watershed, (2) identify impairments, (3) identify and
execute projects or actions to address impairments, (4) assess effectiveness, and (5) adaptively
manage.
A flexible and effective planning requirement may not necessarily prescribe modeling assessment
tools. Though, the watershed prioritization process, identification of impairments, and priority
actions should be based on accepted, defensible scientific and analytical methods.
The permit requirement should be focused on a planning tool instead of data and modeling.
Some data will be needed on watershed characteristics but the emphasis should be to determine
what the Permittee thinks the waterbody needs from a stormwater management standpoint.
The identified projects and actions to address impairments should help inform, guide, and
prioritize other program areas contained in the permits, such as outreach and education, retrofit
planning, capital projects, business inspection, pollutant source identification, and data gathering.
This process can be achieved in a variety of ways and flexibility fostered as long as scientifically
and analytically defensible and transparent to enable accountability.
Department of Ecology (or other Ecology-approved entity, perhaps a subgroup for SWG) should
develop guidance/methodology to support/direct Permittee work. This will be especially useful
for smaller jurisdictions. Possibly, follow approach in IDDE field screening or LID code update.
Overall, we seek planning permit language that allows for effective and defensible process that
provides actionable information to support stormwater management efforts that contribute to
clean water.
4. Transparency & Accountability
Overall, the watershed planning requirement must balance flexibility (Permittee-designed
approach) with accountability (discrete, trackable permit performance measures).
Strong public review processes (with opportunity for involvement and comment) along with
accountability mechanisms must be included to ensure transparency, effectiveness, and
compliance.
5. Broader Application
As long as the watershed planning requirement is structured with enough flexibility to not overly
burden smaller jurisdictions, this permit requirement should be expanded to all Phase I and Phase
II local government permittees.
Commented [LS1]: Just a heads-up that this may raise
concerns of double dipping as one of the sellable points of
the regional monitoring program was to relieve individual
jurisdictions the burden of having to conduct monitoring on
their own.
Commented [ZH2]: Could this be funded by SWG
effectiveness studies funding?
Danielle Shaw: Washington Environmental Council [email protected]
2018 Stormwater Permit Subgroup: Watershed Planning
Guiding Principles
Current Permit Feedback
The current Phase I watershed planning requirement is too prescriptive in its approach to be applied more
broadly. A better balance needs to be struck between prescription and flexibility.
Current language in the first paragraph presupposes stormwater is the primary cause of harm to existing
and designated uses. Recommendation to change language in first paragraph of permit requirement from
“result in†to “fully support,†then add the language of “that contribute to.â€
The price tag and resource commitment required under the current Phase I watershed planning
requirement has proven a heavy lift and would be overly burdensome on smaller Phase II jurisdictions as
well as an unsustainable path for Phase I jurisdictions to continue to pursue.
The current modeling results are not generating transferrable knowledge to build the case that high initial
expenditures can produce payoffs by helping reduce the price tag for other watershed plans.
Some of the prescriptive requirements do not translate well across jurisdictions or watersheds. For
example, B-IBI data is not always an appropriate biological assessment tool for certain types of
waterbodies.
Additionally, current prescriptive requirements are not beneficial for generating output to help inform
flood control programs and other basin planning efforts, potentially proving counterproductive as
resources are driven from those efforts towards this resource-intensive requirement.
Implementation, evaluation, and adaptive management were neglected in this permit requirement.
Guiding Principles for 2018 Watershed Planning Requirements
1. Regulatory Purpose
The purpose of the watershed planning requirement is the protection and restoration of the
beneficial uses of our water bodies.
To meet this purpose, the requirement should generate a planning tool to guide and target
capital actions (e.g., retrofits, facility improvements, restoration) and programmatic efforts (e.g.,
education and outreach, O&M, source control, land use planning, etc.) that support stormwater
management efforts to achieve clean water and ecological function goals.
This purpose is environmental. This planning tool should focus on stormwater, recognizing that
the impairments are likely tied to a broader set of pressures/sources.
2. Outcome-Based Requirement
The requirement should be reframed by its intended outcome: guide stormwater management
investment and programs that contribute to healthy waterways.
The discrete outcome could be a generating a list of prioritized actions and/or targeted programs
necessary to contribute in achieving clean water goals within a 5-year permit cycle. One example
of a discrete outcome could be a certain number of stormwater retrofit projects.
3. Increased Flexibility
An outcome-based requirement could allow more flexibility in the approach to achieve the
prescribed outcome.
The diversity of watersheds and jurisdictional capacity and resources should lend to a more
flexible and effective watershed planning requirement than what the current Phase I permit
language allows.
The scale of the planning effort needs to be flexible as well. Some might be multi-jurisdictional
and large in scale, others might be small and within one jurisdiction. The permit should not
predetermine an acceptable size. Though cross-jurisdictional collaboration should continue to be
supported when the watershed prioritized crosses jurisdictional boundaries.
To that same point, the way watershed sizing has been described in current Phase I requirements
should not be applied to Phase IIs. Smaller jurisdictions may only be able to manage their
watershed as a microcosm within a greater watershed.
A watershed plan should (1) prioritize a watershed, (2) identify impairments, (3) identify and
execute projects or actions to address impairments, (4) assess effectiveness, and (5) adaptively
manage.
A flexible and effective planning requirement may not necessarily prescribe modeling assessment
tools. Though, the watershed prioritization process, identification of impairments, and priority
actions should be based on accepted, defensible scientific and analytical methods.
The permit requirement should be focused on a planning tool instead of data and modeling.
Some data will be needed on watershed characteristics but the emphasis should be to determine
what the Permittee thinks the waterbody needs from a stormwater management standpoint.
The identified projects and actions to address impairments should help inform, guide, and
prioritize other program areas contained in the permits, such as outreach and education, retrofit
planning, capital projects, business inspection, pollutant source identification, and data gathering.
This process can be achieved in a variety of ways and flexibility fostered as long as scientifically
and analytically defensible and transparent to enable accountability.
Department of Ecology (or other Ecology-approved entity, perhaps a subgroup for SWG) should
develop guidance/methodology to support/direct Permittee work. This will be especially useful
for smaller jurisdictions. Possibly, follow approach in IDDE field screening or LID code update.
Overall, we seek planning permit language that allows for effective and defensible process that
provides actionable information to support stormwater management efforts that contribute to
clean water.
4. Transparency & Accountability
Overall, the watershed planning requirement must balance flexibility (Permittee-designed
approach) with accountability (discrete, trackable permit performance measures).
Strong public review processes (with opportunity for involvement and comment) along with
accountability mechanisms must be included to ensure transparency, effectiveness, and
compliance.
5. Broader Application
As long as the watershed planning requirement is structured with enough flexibility to not overly
burden smaller jurisdictions, this permit requirement should be expanded to all Phase I and Phase
II local government permittees.
Commented [LS1]: Just a heads-up that this may raise
concerns of double dipping as one of the sellable points of
the regional monitoring program was to relieve individual
jurisdictions the burden of having to conduct monitoring on
their own.
Commented [ZH2]: Could this be funded by SWG
effectiveness studies funding?
