On September 1 the Maryland Department of the Environment (MDE) submitted the State’s draft Phase I Watershed Implementation Plan (WIP) to the United States Environmental Protection Agency (EPA). The draft presents a range of possible strategies for meeting the State and local Total Maximum Daily Load (TMDL) requirements and will be used to solicit public comment. As the executive summary states:
The current draft version of this Plan is expressly written to solicit public comments on a wide range of pollution control strategy options to restore and maintain the Bay. The Plan will be finalized based on those comments and will serve as a starting point for a Phase II planning process, which will occur in 2011. The table of strategies presented below are options, not final selections, and the options chosen to implement the needed reductions will be selected with the benefit of the public comments received in the coming months.
Given significant time constraints and limitations of current data and models, it is almost certain that the TMDL allocations associated with this Phase I Plan will change during Phase II. This will give interested parties opportunity to comment on the allocations in the Bay TMDL and the implementation strategies needed to achieve a healthy Bay for our families and for future generations.
Based on 2009 loading levels, septic systems and agriculture must make the greatest percentage reduction for nitrogen, urban sources and controlled animal feeding operations (CAFOs) for phosphorous, and CAFOs and urban sources for sediment/suspended solids. If all strategies contained in the draft WIP were implemented, it is estimated the State would exceed its TMDL goals by 30%.
In handling growth, the State is proposing to include some growth projections into the nutrient load numbers but also require offsets for new growth/development. The offsets would be tiered so that new septic systems would have to provide the most offsets while dense urban areas on enhanced nitrogen removal sewerage systems would have to provide the least. The range of options for septic systems includes voluntary upgrades to nitrogen removal technology to hooking up houses currently served by septic systems to public water and sewer to requiring all septic systems within 1000′ of a stream to upgrade to nitrogen removal technology.
The Phase I WIP must be completed by December 31. The Phase II WIP, to be completed in 2011, will include detailed strategies that the State and local governments must follow to reach their TMDL goals. MDE has formed a WIP Stakeholder Advisory Committee to help shape the final form of the Phase I WIP as well as draft the Phase II WIP. Both MACo and the Maryland Municipal League has representatives on the Advisory Committee.
As previously reported on Conduit Street, the State has scheduled a series of four public meetings to discuss the Phase I WIP across the State. Each meeting will be preceded by a special briefing for local governments. The EPA is also holding three regional public meetings on TMDLs.