Stormwater Control Using a Watershed Management Plan

It was a surprise to the residents of southeast Michigan to learn that even if they spent billions of dollars correcting the obvious stormwater problem–combined sewer overflows–the Rouge River would still not meet water-quality standards and, therefore, increased use of the river would not be achieved. The culprits? Other stormwater discharges, illicit connections, flow variability, and failed onsite septic tanks, to name the most important sources of the problem.The Rouge River National Wet Weather Demonstration Project (Rouge Project), initiated in 1992 by the Wayne County, MI, Department of Environment, has learned a great deal about what it takes to restore an urban waterway to its beneficial uses. One of the most important findings is how to use the watershed approach to address the control of stormwater as one of the key steps in the restoration of the river.The Rouge River watershed is largely urbanized, spans approximately 438 mi.², and is home to more than 1.5 million people in 48 communities and three counties. The Rouge Project’s first wet-weather focus centered on the control of combined sewer overflows (CSOs). The conventional wisdom of the project, which was partially funded by USEPA, was that controlling CSOs would restore the water quality in the river. As the project unfolded, however, the monitoring showed that other sources of pollution needed to be controlled before full restoration of the river would be achieved throughout the watershed. In fact, the data showed that even if all of the CSO discharges were totally eliminated, the waters still would not meet water-quality standards. Based on this monitoring information, the focus of the Rouge Project became more holistic to consider the impacts from all sources of pollution and use impairments of receiving waters. The project therefore proceeded on parallel paths: controlling CSOs while pursuing the watershed approach for a total solution to stormwater and other issues. Phased Approach to CSOsThe CSO control program (for the 157 overflow points) in the Rouge uses a phased approach that resulted from negotiations on National Pollutant Discharge Elimination System (NPDES) permits. Phase I of the control program requires the elimination of raw sewage and the protection of public health for approximately 40% of the combined sewer area. Under Phase I, six communities separated their sewers and eight communities constructed 10 basins to evaluate varying sizes and control technologies of CSO basins, known as “demonstration basins.” A two-year period was established in the permits to evaluate the performance of the Phase I CSO control basins. Evaluation findings would then establish the level of control needed for the remaining CSOs in the watershed. Such controls would be implemented in Phase II of the program, which would place controls on the rest of the CSOs in the watershed. Phase I and II controls were to achieve the elimination of raw sewage and the protection of public health. Phase III of the control program would require the installation of additional controls, if needed, in order to achieve water-quality standards in the Rouge River.The Michigan Department of Environmental Quality (MDEQ), with full involvement of the Rouge Project and the local CSO communities, established a process for assessing compliance with the NPDES permits and the Phase I, II, and III control requirements. Based on the evaluation of six of the constructed CSO basins, MDEQ has concluded that all six meet the criteria of the elimination of raw sewage and the protection of public health. By using the phased approach, the Rouge CSO communities have saved hundreds of millions of dollars in construction costs because the size of the basins used in the demonstration was much smaller than the original MDEQ requirements. As a result of the CSO control program to date, 130 mi. of stream are now free of CSO discharges. All of the completed basins are controlling CSOs at a rate of about 4 billion gal./yr. The improvements to water quality in the river are significant as measured by increased dissolved oxygen, greatly improved aesthetics, and reduced suspended solids. Targeting Other Pollutants: A Watershed ApproachWhile the control of CSOs was proceeding, the control of other stormwater quickly emerged as a top priority because discharges in heavily urbanized areas can be a significant source of pollution that prevents the attainment of water-quality standards and designated uses. Stormwater runoff and illicit connections to separate stormwater systems were identified as major sources of pollutants entering the Rouge River. Without efforts to address stormwater runoff in the upstream areas, the major capital investments to control CSOs in the downstream areas would not significantly improve water quality in the river. Later studies emphasized the need to control stormwater runoff responsible for the increasing frequency, volume, and velocity of flood flows in the river. These excessive flows following wet-weather events in the Rouge River watershed were shown to be responsible for significant impairments to aquatic habitat and riparian properties.Based on the study results, the Rouge Project, working with local communities, developed and implemented a stormwater management strategy based on the application of watershedwide management approaches for the Rouge River. The stormwater strategy had six major elements: (1) develop a baseline monitoring program, (2) target investigations in identified problem areas, (3) fund demonstration and pilot projects to remediate pollution sources and reduce flow variability, (4) document institutional options and legal impediments to watershedwide approaches, (5) propose incentives to encourage voluntary participation by communities and other public agencies, and (6) adopt a plan for short-term actions and iterative steps leading to comprehensive, watershedwide stormwater management. Three demonstration subwatersheds were selected to examine how stormwater management plans might differ among various areas within the watershed.It also became clear that water resources management must have the support of the general public to be effective and to become self-sustaining. A locally driven watershed approach to pollution management as a means to achieve management goals is an exciting concept discussed by many but for which there is limited practical experience. This is especially true in urban situations where there are multiple sources of impairment to a water body and stiff competition for limited local resources to address the pollution sources. The Rouge Project has provided an opportunity for a watershedwide approach to restoring and protecting an urban river system by using a cooperative, locally based approach to pollution control. The NPDES General PermitBeginning in 1995, MDEQ, the Rouge Project, and the communities in the Rouge River watershed jointly developed an innovative, watershed-based NPDES General Permit for Municipal Stormwater Discharges, which was issued on July 31, 1997. The General Permit incorporates the following elements:Coverage will be voluntary until the final EPA Phase II stormwater regulations are promulgated.Only public agencies that own, operate, or control stormwater are provided the opportunity for coverage.Subwatershed size is established by the potential permittees during the application process.Application and permit process has limited required actions; the focus is to establish desired outcomes.The General Permit requires the permittee to develop the following:an Illicit Discharge Elimination Plan (IDEP) that has the goal of eliminating raw sewage discharges and addresses failing septic systems and improper connections of sanitary sewers to storm drains and open waterways;a Public Education Plan (PEP) designed to inform residents and businesses about what actions they should take to protect the river;in cooperation with others, a Watershed Management Plan to resolve water-quality concerns, which includes short- and long-term goals for the watershed, delineation of actions needed to achieve the goals, estimated benefits and costs of management options, and an opportunity for all stakeholders to participate in the process;a Stormwater Pollution Prevention Initiative (SWPPI), which includes evaluation and implementation of pollution prevention and good housekeeping practices and the evaluation and implementation of BMPs to minimize impacts of new development and redevelopment;a Monitoring and Reporting Plan that includes a schedule for revisions to the Watershed Management Plan.The IDEP and PEP are submitted to MDEQ at the time of application for the General Permit, and implementation of these plans begins when the MDEQ issues a Certificate of Coverage to a community or agency. Within six months after the issuance of a Certificate of Coverage, the General Permit requires a public involvement plan to be submitted for approval by the state. This plan identifies the approaches that will be used within the hydrologic area to involve stakeholders in the development of a watershed plan that must be completed within 18 months after the Certificate of Coverage is issued. Once a consensus watershed plan has been completed, each agency and community within the hydrologic unit must prepare and submit for state approval its own pollution prevention initiative, the SWPPI, that identifies actions and schedules to address the pollution concerns identified in the consensus watershed plan. The watershed stormwater management plans developed by the communities and other public agencies do not require state approval; however, the individual pollution prevention initiatives emanating from the watershed planning process require state approval as the activities specified in the initiatives become permit requirements upon approval.Forty-five communities and agencies that own, operate, or control stormwater systems in the Rouge River watershed obtained coverage under Michigan’s watershed-based General Permit. More than 95% of the watershed area is therefore covered.

Mouth of the Rouge RiverMost communities and agencies within the Rouge River watershed will be required to obtain a permit under the federal NPDES Phase II regulations. MDEQ sought and obtained concurrence from EPA that the requirements of the watershed-based stormwater permit would satisfy the initial requirements of the Phase II stormwater regulations. EPA did endorse the use of the permit in lieu of permits that would otherwise be required by those regulations. At the heart of the MDEQ watershed-based stormwater permit is the development of the watershed management plan for each identified subwatershed. The seven subwatersheds within the Rouge River watershed have formed individual Subwatershed Advisory Groups (SWAGs) with representation from the local communities and agencies that own or control stormwater facilities within each of the prescribed hydrologic boundaries. All seven subwatershed management plans have been completed and are being implemented. Each community and public agency is now developing its SWPPI for MDEQ review and approval to maintain the Certificate of Coverage. The SWPPIs must be consistent with the adopted subwatershed management plans and must identify scheduled actions the community will undertake to achieve the long-term goals of the subwatershed management plans. The Michigan General Stormwater Permit is quite flexible and allows those seeking coverage under the permit to use a wide variety of approaches to meet the public education, illicit connection/illegal discharge, and public involvement requirements. This flexible framework has allowed communities to experiment with various approaches that recognize local constraints and seizes upon unique opportunities to meet the desired outcomes. While the basic requirements for what must be in the watershed plan are detailed in the regulations, the permittees within a hydrologic or subwatershed unit are allowed considerable freedom in deciding on their own priorities, remedial actions, and schedules. Pollution prevention initiatives that are expected to be proposed by the communities will likely involve a commitment to continue or expand current activities such as soil erosion and sedimentation control, implement new activities to address priority issues such as failing septic systems, and implement regional projects to reduce the frequency and velocity of storm flows in the river.One of the primary goals of the Rouge Project is to demonstrate that an urban river system can be restored and protected using a watershed approach. Currently, Rouge Project activities are a combination of meeting regulatory requirements and other voluntary activities being coordinated by subwatershed. There is a clear interrelationship of the pollution sources within a watershed that demands an interrelated approach to a solution. Therefore, the heart of the success of a watershed protection and/or restoration effort is the development of a sound watershed management plan for a specific watershed. The watershed approach has emerged as the most cost-effective and logical approach to stormwater management.Applying the Watershed Approach to Other ProgramsThe State of Michigan has incorporated watershed planning components into a number of water resource management programs. Three such programs are summarized below. TMDL Program. Various segments of the Rouge River are included on the federal Clean Water Act Section 303(d) list for various parameters. The total maximum daily loads (TMDLs) for these segments are not scheduled for completion until approximately 2005. The river will require multiple TMDLs (approximately 15) that might result in conflicting implementation strategies in the watershed as a whole. Under EPA’s proposed TMDL regulations, use of the watershed approach is encouraged, an approach already being implemented in the Rouge Project.Clean Michigan Initiative. In July 1998, the State of Michigan passed and began implementing its Clean Michigan Initiative, a $675 million general obligation bond dedicated to fund projects for “Clean Water, Clean Parks, and Clean Communities.” Funding awards under two categories of grants–the Nonpoint Source Pollution Control Grants and the Clean Water Fund–are based on an “approved” watershed management plan. Water Quality Trading Program. The State of Michigan is in the process of completing its Water Quality Trading Program rules. Through this program, the trading of nutrients in impaired water bodies (for which TMDLs have not yet been developed) can occur only where an approved watershed management plan has been developed. Unlike other “approvable” watershed plans, the watershed management plan for the trading program must include a “cap” and allocations. A demonstration basin under constructionAs described earlier, the seven subwatershed advisory groups in the Rouge watershed have developing watershed management plans as required under the Michigan General Permit. Obviously it is desirable to develop only one “comprehensive watershed management plan” that will meet stakeholder goals and objectives as well as all applicable program requirements of any other programs that emerge. Therefore, the Rouge Project subwatershed management plans have a goal of being comprehensive watershed management plans that will meet objectives of multiple programs. By doing so, both the watershed communities and regulatory agencies will save time, money, and effort by having one plan that fulfills multiple objectives. In addition, these comprehensive plans will provide much-needed certainty to the communities, counties, and other stakeholders in planning for watershed management activities and expenditures. Rouge River outfallA comprehensive watershed management plan must address all sources of pollution (CSOs, sanitary sewer overflows, stormwater, illicit connections, failed onsite sewage disposal systems, various nonpoint sources, and so on) reaching the river as well as all of the other stressors that adversely impact the achievement of water-quality standards (e.g., lack of habitat, flow variability, increasing imperviousness). A comprehensive watershed management plan can specify the amount of pollution or other stressors that need to be reduced/addressed to meet water-quality standards, and the plan can allocate pollution control or management responsibilities among sources in a watershed. This appears to be the thrust of the national watershed approach.Finding a Balance for Designated UsesAt the heart of the Clean Water Act and its subset programs is undertaking those actions necessary to meet water-quality standards and the related designated uses. The most important water-quality standard is meeting public health protection criteria. Instituting the control programs needed to meet public health criteria is, technologically, fairly straightforward. Meeting the aquatic-life designated use is more complex, however. This requires some discussion because of the tie between use of the watershed approach and achieving water-quality standards.At present, the state designates an aquatic-life use, usually expressed as a fishery use. In almost all cases, that designation is established as the endpoint of the final water-quality standard to be met. It assumes that if the designated water quality is met, the full range of aquatic life will be achieved. Often that is not a valid assumption.The quality and quantity of aquatic life, especially any freshwater fishery, is closely tied to the environmental conditions of the water body in question and the surrounding lands that drain into it (i.e., the watershed). For these reasons, maintaining a suitable fishery requires management of both a water body and its watershed. Management of any natural resource has two components: protection and restoration. Watershed protection–actions that prevent degradation of the physical, chemical, and biological components of the watershed–is the most cost-effective and long-term approach to watershed management. Maintaining a sustainable fishery in many watersheds, however, often involves restoring some degraded or missing attribute important to fish survival. These could include a specific habitat important at some point in a fish’s life cycle, or some aspect of water quality or water quantity such as dissolved oxygen, or the seasonal water-flow regime.In summary, the designated uses assigned to a water body must not ignore the balance between the physical, chemical, and biological conditions needed for the specific species of fish to be protected, warm-water or cold-water. A comprehensive watershed management plan will do more than just meet water-quality standards. It will delineate those measures needed to restore the ecological health of the waterway.The water-quality standards and related designated uses are not being met in the Rouge River watershed. The reasons for this are multiple, such as point sources (CSOs), stormwater runoff, illicit connections, and failed onsite systems. Equally important factors to the nonattainment of water-quality standards are other contributing problems such as flow variability in the streams, lack of instream habitat for all kinds of aquatic life needed in a healthy ecosystem, lack of wetlands adjacent to the river, and increased imperviousness in the watershed, to name a few. In an urban environment, addressing all of these factors is extremely complex. An Understandable ProcessWatershed management plans provide an excellent framework to coordinate the numerous regulatory and nonregulatory programs associated with water resources management. Some of the multiple program requirements that can be coordinated through use of a single watershed management plan include (but are not limited to) reissuance of NPDES permits on a watershed basis, implementation of the water-quality trading programs, implementation of the Section 319 nonpoint-source program, development and implementation of Watershed Restoration Action Strategies envisioned under the federal Clean Water Action Plan, implementation of monitoring programs, and addressing the requirements of the TMDL program. This latter program provides some good opportunities for using a watershed management plan to meet desired objectives. Nothing in the current law requires a watershed approach to addressing water-quality problems, but federal agencies want to offer incentives to develop such watershed management plans. By taking a more comprehensive approach to restoring the health of the aquatic system in the watershed, a comprehensive watershed management plan can result in improvements in environmental conditions that are mutually reinforcing, with higher long-term success rates. Water bodies impaired by polluted stormwater runoff in most instances will require a watershedwide effort to achieve the necessary restoration and clean-water goals. Development of a multiple-objective, comprehensive watershed management plan is also an opportunity to identify and demonstrate innovative approaches to restoring water quality and protecting public health and the environment. A water-quality restoration effort on a watershed scale, rather than river-segment scale, also offers citizens and other stakeholders better opportunities to participate in a water management process that is understandable and meaningful. Achieving multiple objectives through a single watershed plan is very important to the stakeholders in the Rouge River watershed for four main reasons. First, virtually all of the more than 50 communities and agencies in the watershed that own, operate, or control stormwater discharges have volunteered for coverage under the General Permit; development of watershed management plans is a requirement of the permit. Those plans should be as complete as possible so they will be able to serve many purposes, as discussed above. Second, the water program is moving in the direction of using the watershed approach. Nationally the minimum elements of a watershed management plan have not been defined through any consensus fashion to date. Those elements might emerge over time as more experience is gained nationally in implementing the watershed approach. As discussed above, the Rouge Project has defined those minimum elements. These elements build on the pioneering effort of the Michigan General Stormwater Permit. Third, large portions of the Rouge River do not meet water-quality standards and therefore will be faced with the need to develop TMDLs in the very near future. The Rouge Project is showing how a comprehensive watershed management plan will completely fulfill the needs of the TMDL program. It is important to note that EPA has embraced the concept that a watershed management plan can be the equivalent of a TMDL. Fourth, a successful comprehensive watershed management plan as envisioned will result in restoring the Rouge River much faster.The Rouge Project envisions the comprehensive watershed management plan (tied to the TMDL) to set pollution reduction responsibilities among the identified stressors that are causing or contributing to the nonattainment of water-quality standards. This goes beyond doing just a load allocation and addresses all of the stressors causing the nonattainment. The Rouge Project sees this as being on the cutting edge. The Rouge Project will demonstrate to others the advantages and workability of the watershed management approach, its relationship to the TMDL program, and the advantages of using this comprehensive approach to restoring water quality. Conclusions The Rouge Project and others have shown that by holistically addressing all sources of pollution, an effective action plan can be implemented to address impairments and restore river uses. An overall integrated solution that addresses the physical, chemical, and biological stressors in a waterway is the most cost-effective way to proceed. Without this integration, there is a series of “add on” programs that miss an opportunity to encourage an integrated program that addresses all sources of ecosystem stress in a cost-effective, prioritized manner. An integrated approach also facilitates achieving multiple program objectives through a single watershed management plan.The watershed approach is a new way of doing business by the states and EPA. A locally driven approach requires a sharing of power with the regulatory agencies. Overcoming the command and control philosophy is not easy.It is important to note that watershed planning and implementation does not just happen. It takes time and effort. One of the main issues the Rouge Project has faced is forging a new regulatory framework and building new institutional relationships. The Rouge Project has learned that local units of government want meaningful self-determination in deciding how to achieve water-quality objectives. Increased local accountability garners local support and generates peer pressure. It is also critical to have flexibility and, at the same time, accountability. It is important to look at the resource, beyond individual dischargers, using a range of indicators.What does the future hold for the Rouge Project? The project anticipates a comprehensive process to truly bring together programs dealing with pollutants (such as general stormwater runoff), CSOs, and other sources and other impediments (for example, flow and habitat destruction and aesthetics). These processes will require innovative regulatory approaches, workable institutional arrangements, and use of the holistic approach. A key item will be to build in accountability for water-quality/ecosystem health at the local level.In conclusion, local communities in southeast Michigan and the state regulatory agency are attempting, for the first time, a consensus-based, cooperative approach to watershed management. The watershed management plan will form the basis for implementing watershed goals and objectives that will result in improved water quality and pollution control. This program implements the watershed approach endorsed by EPA and others and should facilitate watershed-based integration of control programs for different pollution sources, such as stormwater and CSOs, that might be present within a large urban watershed. This program empowers local governments and their stakeholders in identifying problems, choosing from alternative solutions, establishing priorities and schedules, and developing common strategies with neighbors. Communities and others involved in this new program are also addressing such issues as coordination of subwatershed efforts within larger subwatersheds. Flexibility and innovation must be encouraged in water resources management. Communities should actively use the watershed approach. The Rouge Project is a working demonstration of the watershed approach to restoring an urban river system. Tangible benefits of this approach are faster environmental improvements and cost savings. A major benefit is achieving multiple objectives through a single watershed plan. And finally, the Rouge River is being restored.Use of the watershed approach and the development of watershed management plans provide a perfect vehicle to tie together many aspects of the water program. Achieving multiple objectives through a single watershed plan is very important to the stakeholders in the Rouge River watershed. It is hoped that this effort and the work of the Rouge River National Wet Weather Demonstration Project will continue to identify and quantify the benefits of cooperative, watershed-based efforts to protect and restore our nation’s water resources.

The obvious questions that need to be asked of the Rouge Project are: Is the watershed approach working? Is the water quality improving? The answer to both is a resounding YES! The watershed approach is achieving remarkable resul