WATERSHED-BASED PERMITTING IN NORTHERN KENTUCKY

According to the United States Environmental Protection Agency (USEPA), watershedbased NPDES permitting is an approach to developing NPDES permits for multiple point sources located within a defined geographic area (i.e., watershed boundaries) (USEPA, 2003). In establishing point source controls in a watershed-based permit, the permitting authority may focus on watershed goals, and consider multiple pollutant sources and stressors, including the level of nonpoint source control that is practicable. Sanitation District No. 1 of Northern Kentucky (District) has secured funding from USEPA through a cooperative agreement to develop an approach for watershed-based permitting (Clean Water Act Section 104(b)(3)). The District is responsible for the collection and treatment of Northern Kentucky's wastewater, as well as regional storm water management. The District serves 33 communities in Boone, Campbell, and Kenton Counties of Northern Kentucky.The watershed-based permitting approach discussed in this paper takes advantage of the regional extent of the District's service area, as well as an extensive database of water quality and GIS information that the District has compiled for their service area. It is expected that a single permit would be issued for discharges under the District's control within a watershed, in lieu of the KPDES permits currently issued to the District, such as those related to stormwater and sanitary sewer issues, including CSOs.The watershed permit being explored would prescribe an approach toward controlling all watershed sources of pollution, and prioritizing and selecting controls. The approach is based entirely on the concept of adaptive watershed management, which is a means to ensure attainment of water quality standards in a cost-effective and timely manner. This approach is focused on doing better science, which will lead to more effective decisions and faster progress in improving water quality.It is generally not possible to accurately specify individual controls or numeric limits at the onset of the permitting process because information on water quality conditions and stressors is incomplete. The permit instead would require adherence to a detailed adaptive watershed management process, which requires continual steps of controls and monitoring with progress towards attaining water quality standards while maximizing the efficiency of pollution control efforts. This progress would be ensured through development of a detailed and enforceable implementation plan for improving water quality.To date, an approach to watershed-based permitting has been developed and this approach has been discussed with both the Kentucky Division of Water and the USEPA. A feasibility assessment concluded that this watershed-based permitting approach provides a significant improvement over the existing, traditional NPDES permitting approach and the District and the Kentucky Division of Water have agreed to pursue additional dialog on the development of a draft watershed permit for Banklick Creek, focusing on wet weather discharges. This watershed was selected because it is impacted by urban storm water runoff, sanitary sewer overflows, septic systems and rural runoff. The District's waste water treatment plant does not discharge into the Banklick Creek watershed.