December 18, 2013

1. Leon River Watershed Protection Plan: Addressing EPA Comments PARSONS December 18, 2013

2. EPA Comments • 26 pages of comments that focused on several themes • WPP is not accepted at this time • Parsons has been contracted to respond • Detailed responses to be prepared based on stakeholder guidance • Responses will be provided to working committee for feedback and consensus

3. General Comments • “Challenges to acceptance of the document under the NPS Program Guidelines focus on • a clear commitment to state water quality standards as the restoration goal, • BMPs and water quality goals that address nutrients, chlorophyll-a, and dissolved oxygen, • size of the watershed, and • lack of sufficient documentation of modeling efforts to answer technical questions about sources, load reductions, and the level of implementation needed for desired water quality outcomes. • These factors make it unclear to what degree water quality restoration would be accomplished through implementation of the WPP, and should be addressed before we can accept this plan.”

4. Bacteria-addressing the 126 goal • Issue: Not stating implicitly that the watershed will meet WQ standards • Most watersheds below the current standard of 126 #/100 ml E. coli, but three watershed would not be compliant with current standard • WPP states a goal of 206 #/100 mL due to the potential option of a standards revision • It didn’t pass, but standards revision is up again • WPP states one watershed will not be compliant at 206 • Group Discussion: do stakeholders want to work towards achieving current “standards” (today or into the future) throughout the watershed • If so, timelines and how to be discussed later • Risk: without stated goals of achieving standards, federal funds may not be available • If standards do change we can outline a moving target standard through adaptive management, but the main issues is that the watershed “will” achieve “standards.”

5. Nutrients & Chlorophyll A • Fact: The watershed is not meeting certain water quality criteria beside bacteria: nutrients and chlorophyll A • Issue: The WPP states only that it is expected that what will be done for bacteria will also reduce these parameters with no specific projects, quantification of reduction, or other discussion to show a focus on nutrients • Group discussion: do stakeholders want to take a holistic approach to the watershed and add strength to the discussion about addressing nutrients • Cropland would be a land use category that would likely get more attention • The model is not calibrated to address nutrients and discussion would likely rely on lateral evidence or discussion of specific projects

6. Dissolved Oxygen-Resley Creek • Issue: as data is continuously gathered, DO in Resley Creek has become an issue • Most likely related to nutrient sources • DO has not been discussed in the WPP • Group Discussion: Do stakeholders want to add language to address DO in Resley Creek • The discussion about nutrients will address the projects and actions

7. Watershed Size • Issue: the Leon River watershed is not a typical watershed size for a WPP, it is too big. • The WPP does a good job of addressing all the regions • Only three watershed are not compliant • Recommendation: Keep the watershed size as the plan adequately addresses the entire watershed • Discussion: • What strength can be added to the watersheds that are not compliant to out more focus?

8. Next Steps • Prepare response to comments; feedback from TSSWCB • Give WC time to review and provide feedback • Submit comments to EPA through TSSWCB • Timeline for submitting revisions • Prepare response to comments to EPA (Jan) • Amend contract • Conduct needed technical elements • Revise WPP sections • Provide Revised WPP to WC • Incorporate comments • Resubmit to EPA