Example TMDL Implementation Plan for cities

The Gresham Implementation Plan is presented as an example of an approvable TMDL implementation plan for a large to medium size municipal designated management agency (DMA). This implementation plan may serve as a template for other cities and counties with similar responsibilities, especially those with a Municipal Separate Storm Sewer System Permit (MS4 Permit) – to restore the quality of impaired waterbodies and to protect human health, aquatic life, and other beneficial uses associated with these water resources.

Background

The City of Gresham environmental program staff developed a TMDL Implementation Plan (IP) for TMDLs in the Willamette and Sandy River Basins. Specifically, Gresham staff developed an implementation plan that addresses permit and TMDL requirements for four separate TMDLs, in five watersheds, covering 10 water quality parameters. The implementation plan combines narrative sections (Volume 1 - Overview, Volume 2 – Nonpoint Source Bactieria IP, and Volume 3 – Nonpoint Source Temperature IP) with a matrix (Table 3) that is the core of the plan.

Implementation Plan

Volume 1

The Overview volume describes Gresham’s specific jurisdictional situation with multiple watersheds and TMDLs.

Volume 2

In the Nonpoint Source Bacteria Implementation Plan Gresham identified implementation plan measures to address bacteria from sources not covered by the MS4 permit but within the City’s boundaries.

Volume 3

In the Nonpoint Source Temperature Implementation Plan Gresham documented a strategy to protect and restore streamside vegetation throughout its jurisdiction.

Table 3 of the plan (xls) (pdf)

Provides a summary of implementation measures and associated regulatory drivers. Gresham’s commitment to implement each measure and performance measures to evaluate progress are clearly detailed in the table. It is expected that this comprehensive approach to TMDL implementation will strengthen linkages of multiple regulatory programs, facilitate adaptive management of the watersheds within the City’s jurisdiction, and streamline regulatory reporting requirements.

Benefits

There are several benefits with this implementation plan format:

• The Narrative sections meet regulatory requirements
• The Narrative sections can be tailored to meet a DMA’s specific situation
• The Narrative can describe changes over time from the original plan (adaptive management)
• The Matrix simplifies and summarizes federal, state, and local regulatory programs into a single document
• The Matrix can be submitted annually to fulfill reporting needs for both municipal separate storm sewer system (MS4) permit and TMDLs
• The Matrix can be easily updated over time
• The Matrix can track and assess the DMA’s surface water protection and restoration efforts.

A Model Process for Developing TMDL Implementation Plans