Memo from G. Tracy Mehan, III Committing EPA's Water Program to Advancing the Watershed Approach
Dec. 3, 2002
|SUBJECT:||Committing EPA's Water Program to Advancing the Watershed Approach|
|FROM:||G. Tracy Mehan, III /s/
Regional Water Division Directors
A Renewed Commitment to Watershed Management
We face many complex and challenging environmental problems related to the water environment. Unlike the problems of the past, today's problems are often subtle, chronic, and inter-related. Addressing 21st century problems like polluted runoff, suburban growth, drinking water security, ground water/surface water interactions, invasive species, microbes in drinking water, and atmospheric deposition demands a modern approach to environmental protection - an approach grounded in sound science, innovative solutions, and broad public involvement.
About a decade ago, EPA embraced and took steps to encourage a watershed approach to better address water quality problems. I firmly believe that such an approach, which focuses multi-stakeholder efforts within hydrologically defined boundaries to protect and restore our aquatic resources and ecosystems, offers the most cost-effective opportunity to tackle today's challenges. Administrator Whitman shares my belief. She feels strongly that a watershed or "place-based" approach is one of the most important environmental guiding principles for her as well as for this Administration. By working together with a diverse array of partners, I believe we can identify and implement successful strategies to maintain and restore the chemical, physical and biological integrity of our waters. No doubt, many of these strategies will be tailored to specific problems in specific communities. Hence, the importance of the watershed as a social and hydrological reality. Here is where communities, neighbor to neighbor, can engage, educate and persuade one another in a mutual quest for shared goals.
Although a decade of effort has resulted in general awareness of the watershed approach within the Agency, recent evaluations show substantial gaps in actual implementation. The watershed approach should not be seen as merely a special initiative, targeted at just a selected set of places or involving a relatively small group of EPA or state staff. Rather, it should be the fulcrum of our restoration and protection efforts, and those of our many stakeholders, private and public. Failure to fully incorporate the watershed approach into program implementation will result in failure to achieve our environmental objectives in many of our nation's waters.
I want to reaffirm the Office of Water's commitment to advancing the watershed approach. Consequently, I am creating a Watershed Management Council (WMC) comprised of Headquarters and Regional representatives. This group is charged with overseeing efforts to address the specific issues listed below, as well as identifying and exploring other ways to advance the watershed approach. I am asking each Office Director (OWOW, OST, OWM, OGWDW, and AIEO) to designate an SES-level representative for the Council, and I am inviting each Regional Water Management Division Director to do the same. Please provide the names of your representatives to Walter Mugdan of Region 2 by December 31, 2002. This group will begin its work at a kickoff meeting to be held before the end of January. Among the specific issues to be addressed under the leadership of the WMC are:
- The watershed approach can help us integrate and focus our programs. I would like the Council to:
Review the findings of the Program Integration Team (PIT)
The PIT and other recent evaluations made recommendations for improving the coordination of programs on a watershed basis. I want the WMC to review these findings and recommend to me specific actions Headquarters and/or the Regions can take to make these recommendations a reality. Particular attention should be paid to ways to better integrate CWA and SDWA implementation.
Create models of program integration
The Watershed Initiative, pending Congressional appropriation, will fund projects in up to 20 selected watersheds in 2003. I would like EPA to make these places "laboratories" for integration of EPA and other federal programs. Consistent with local objectives, I want the Regions to develop program integration strategies for each selected watershed and present these strategies to the WMC within 6 months of the announcement of the awards. If an integration strategy is not consistent with local objectives for a particular watershed, I would like to know why.
Expand cross-program training In order for cross-program integration to work, EPA, state, and other federal agency staff need to have a better overall understanding of key CWA and SDWA programs and other federal and state tools for watershed protection. I would like the WMC to establish annual goals starting in the calendar year 2003 for providing training to HQ and Regional water employees on the basics of our key programs under CWA, SDWA, and other relevant statutes.
Internal Management Systems
I have heard from many that EPA's internal accountability mechanisms, such as Headquarters-Regional management agreements and employee performance standards, do not offer adequate incentives and can create barriers to program integration on a watershed basis. The WMC should look for ways to remove existing barriers and create new incentives.
Funding Local Watershed Strategies
Local partnerships are finding it challenging to fund the implementation of holistic watershed strategies because of narrowly-defined, balkanized grants and loans. I would like the WMC to explore ways to address this by identifying "best practices" and models for streamlining processes and other barriers to watershed funding.
Local Capacity Building
Local watershed partnerships report substantial need for a wide array of training and technical assistance. EPA and state water programs cannot provide help to all of the thousands of watershed partnerships that are now operating. We need to bolster the efforts of academia, nonprofits, local governments, and businesses. EPA could help fill some of this gap by:
Expanding support to 3rd-party providers
As an initial step, I want the WMC to recommend ways to provide additional support to our partners' efforts, such as helping other organizations expand their training and technical assistance to local entities.
Increasing direct EPA involvement in training and technical assistance.
I believe that our assistance, if strategically placed, can be extremely valuable in helping local watershed partnerships. Since my arrival here, I have been impressed with the tremendous amount of expertise that resides in EPA, and I would like to increase our presence in those places where we can be of most value at the local level. I expect the WMC to find ways to accomplish this, such as the use of IPAs, internet broadcasting, increased EPA travel, and other strategies. To support the WMC, I am tasking the OW Budget staff with examining internal barriers to having sufficient travel funds.
Assistance to States and Tribes
As you know, there can be many variations in the specific approaches states use to implement programs on a watershed basis. It is not my intention that EPA impose or specify a particular watershed management model. Rather, we should support states in implementing the approaches they find work best for them. I want to expand our efforts to help states that are seeking assistance in adopting a statewide watershed approach; and I want to assist those states that have already begun to implement watershed management for certain elements of their programs to broaden their application where practicable. I would also like to have EPA's Statewide Watershed Approach Framework document updated to better reflect this philosophy.
Tribes are key partners in demonstrating the value of the watershed approach. We need to find additional ways to help tribes build the watershed approach into their programs.
I cannot emphasize enough the importance of innovation to EPA's future. Watersheds are ideal for experimenting with market-based incentives and trading, and for devising new, non-traditional methods to provide data and information in ways that allow stakeholders at the local level to better assess and address their own unique problems. For example, I believe the use of watershed-based permits can help foster these kinds of innovations. As such, I would like to accelerate our efforts to implement innovations in several program areas. Specifically, I would like to see the following:
- Implement innovations set forth in the Strategy for Water Quality Standards and Criteria.
- Expand the use of innovative approaches to monitoring and information collection in watersheds (using landscape modeling and probablistic designs).
- Use integrated approaches to TMDL development in watersheds; and use the watershed approach to attain water quality standards, obviating the need for TMDLs in a number of watersheds.
- Promote the use of watershed plans to guide greater investment of SRF funds to protect source water, wetlands, and address nonpoint sources.
- Accelerate efforts to develop and issue NPDES permits on a watershed basis. To accomplish this, I'm asking OWM to issue, in final form, the watershed-based permitting policy statement and to work with the Regions to:
- Develop and implement a "roadmap" for advancing watershed-based NPDES permitting activities.
- Implement the watershed-based NPDES permitting policy immediately in those Regions that administer the NPDES permit program.
- Have regions identify watershed-based permit case studies. If no regional examples already exist, create watershed-based pilots.
- Include watershed-based permitting approaches as priority decision criteria for Water Quality Cooperative Agreement funding.
- Characterize the permit universe to determine permits or groups of permits that may be a high priority for reissuance based on watershed specific goals, impacts, and expected results.
Aggressively promote trading and other market-based incentives in watersheds.
Foster innovation through ORD's research agenda.
Rulemakings and Guidance
I've heard that, on occasion, EPA rules and guidance can unintentionally create barriers to implementing watershed approaches. The WMC should recommend a process to ensure that this does not happen in the future.
I am very enthusiastic about this endeavor. The watershed approach is essential to address our most pressing water issues, and now is the right time to focus and re-invigorate our efforts to more fully institutionalize the approach - both on the ground and as a cornerstone of our core water programs. I greatly appreciate your continued support for the watershed approach, as well as your active leadership in this particular effort.
cc: Christine Todd Whitman, Administrator
Linda Fisher, Deputy Administrator
Tom Gibson, Associate Administrator, Office of Policy, Economics, and Innovation