ID, OR & WA Partnership with EPA for Developing TMDLs | Region 10 | US EPA

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ID, OR & WA Partnership with EPA for Developing TMDLs

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PURPOSE

BACKGROUND

EPA REGION 10'S PHILOSOPHY

GUIDING PRINCIPLES

SUMMARY OF RECOMMENDED CHANGES

EPA AGREEMENTS (MOA/MOU) WITH IDAHO (pdf file, 54 pgs), OREGON AND WASHINGTON (pdf file, 22 pgs)



PURPOSE

This document outlines the Partnership Philosophy between EPA and the States of Idaho, Oregon and Washington that will direct TMDL development. We begin this Partnership recognizing the importance of other partnerships that influence TMDL development and implementation; and have designed a TMDL process that is open to all partners.


BACKGROUND

The states of Idaho, Oregon and Washington working with EPA have the task of developing TMDLs for over 2000 waters over the next ten years. The states have the primary responsibility for developing TMDLs. EPA has primary responsibility for providing support and final approval.

As partners in this effort, EPA, ID, OR and WA agree that this workload places unusually high demands on available resources - now and in the future. In plain words, “We won’t get this job done in time if we proceed as we have to date.” We recognize our limited resources and our need to meet TMDL development commitments. Within these constraints we are committed to maximizing environmental benefit. We welcome others in joining us to achieve our goal of developing TMDLs.

With this realization and several years of start-up experience and learning about the work required to develop TMDLs, representatives from EPA, Idaho, Oregon and Washington formed a team to find better ways of working together to get this job done on time.


EPA REGION 10'S PHILOSOPHY

First and foremost - in our partnership, we will work together toward making an environmental difference on the ground. We see TMDLs as one of many tools that can be used to help make this difference. We will emphasize early collaborative involvement and consultation. We will employ division of labor to expedite TMDL development.

Our second commitment is to work together to meet our obligations to develop TMDLs, focusing on meeting the commitments laid out in our TMDL development schedules, while producing, as best we can, a legally defensible document.

We will adopt processes, systems and attitudes of partnership in developing TMDLs. As we work together to build these processes, systems and attitudes we will seek to balance our people and money resources, our technical and environmental expectations and our legal and schedule constraints.

In order to realize earlier success on the ground, we will employ an Adaptive Management strategy. Adaptive Management focuses on starting us on the path toward making an environmental difference even though we probably will not have found the one perfect solution. Adaptive Management assumes that the TMDL and the watershed to which it applies will be revisited over time to make adjustments that continue to move toward achieving environmental protection goals.


GUIDING PRINCIPLES
  1. We will have a consistent process that allows for flexibility and judgement in developing effective TMDLs that employ adaptive management to fill gaps we encounter. The TMDL development process must be flexible enough to reflect differences between watersheds.
  2. We see TMDLs as one of several tools of water quality management and will approach our work from a holistic watershed management perspective. We agree to consider other work going on in the watershed.
  3. We agree that getting started on the ground is critical - we will avoid analysis paralysis. Each TMDL should recognize current actions and promote immediate water quality improvement and, when appropriate, include an adaptive management strategy which includes “revisiting” TMDLs over time.
  4. We will emphasize dividing the work among ID, OR, WA and EPA in order to better utilize our resources and reduce transaction costs. EPA and the States will decide who has the lead for developing each TMDL and the level of effort expected. Agreement will be reached on complementary work and roles to allow all to be successful. The agreement on the approach will continue even if personnel change.
  5. We agree to identify and resolve technical and policy differences in a collaborative way and to develop a timely conflict resolution process.
  6. We will categorize TMDLs. We have the highest expectations of the TMDL analysis for high priority TMDLs, where environmental and legal risks are highest. High expectations do not necessarily mean high EPA involvement.
  7. EPA’s primary involvement will be early in the process, and will consist primarily of working with the States on the information gathering, the problem statement, and the project plan phases of the TMDL. Both EPA and states expect and encourage early participation of other partners.
  8. EPA will work with Tribes and others to identify issues and concerns early. EPA will resolve conflicts early in the process to avoid delays and re-work that comes from raising issues late in the process.
  9. States and EPA are responsible for developing the TMDLs and as such are accountable for their outputs. Should there be a legal challenge, the lead agency in developing the TMDL will take the lead in defending the technical work and the other party will provide support.
  10. We agree that the EPA final review process must be expedited. Generally, because of EPA’s early involvement, review will consist only of a presence/ absence review of legal requirements. EPA staff who provide input are accountable for their input; the state is accountable for how EPA’s input is applied.
  11. We will periodically jointly evaluate the overall TMDL Work Process to determine what is working and what is not working and make adjustments that allow us to continue to work in partnership. We acknowledge uncertainties such as regulation changes and ESA compliance may need to be addressed in the future.

SUMMARY OF RECOMMENDED CHANGES


You will need Adobe Acrabat Reader, available as a free download, to view this above file. See EPA's PDF page to learn more about PDF, and for a link to the free Acrobat Reader.
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