General Background
Most of the Rouge River Watershed has volunteered for coverage under the MDEQ General Storm Water Permit. One of the requirements of the permit is the need for permittees to develop a watershed management plan. The seven subwatersheds in the Rouge Watershed are now developing watershed management plans as required under the General Storm Water Permit. The purpose of developing a watershed management plan is to delineate the actions needed to restore the Rouge River so that its waters will meet the established water quality standards and the related designated uses.

To be a comprehensive watershed management plan it must result in the attainment of water quality standards. The plan must address all sources of pollution (i.e. combined sewer overflows (CSO), sanitary sewer overflows (SSO), storm water, illicit connections, failed on-site sewage disposal systems, various non-point sources, etc.) reaching the river as well as all of the other stressors that adversely impact the achievement of water quality standards (i. e. lack of habitat, flow variability, increasing imperviousness, etc.).

Under the current law, for those waters not meeting water quality standards, an analysis must be made of the sources of waste causing the water quality standards violation, and then a total maximum daily load (TMDL) must be developed which will determine the limit on the amount of loading for a specific parameter in the waste allowed to be discharged to the river. A TMDL must be developed for each parameter for which there is a violation of water quality standards. In complex situations such as urban rivers like the Rouge River developing individual TMDLs on each specific parameters may be a futile effort because it will not result in meeting water quality standards for several reasons. For example, the individual parameter specific TMDLs may result in the implementation of conflicting control strategies. Or just controlling the discharge of pollutants from point and non-point sources (as required by the TMDL process) may not result in the achievement of water quality standards due to other physical, chemical or biological conditions that must be addressed and corrected.

Wayne County's Rouge River National Wet Weather Demonstration Project has learned from its extensive data collection activities and modeling that there is a clear inter-relationship of the physical, chemical and biological conditions within a watershed that demands an inter-related approach to a solution. In order to achieve water quality standards and associated designated uses within the Rouge River, it has become abundantly clear that pollution management must be addressed in a holistic fashion that considers the inter-relationship between the impacts from all sources of pollution and other stressors on the receiving water. Only focusing on some sources of pollution or a group of sources and not addressing other stressors will not achieve the desired results nor will it achieve the acceptance of the residents of the watershed. It is mandatory to analyze all of the various sources of stressors to the water quality problems in a watershed-physical, chemical and biological-and decide how to get a handle on the priority of dealing with those problems. It is critical to establish a hierarchy of the stressors based upon the adverse water quality impacts of those stressors. It is equally important to keep reinforcing, at a watershed level, the concept of prioritizing the control of those sources and the other stressors to get desired environmental protection. It may take a long time to correct some of these pollution sources or other physical, chemical or biological stressors so it is important to prioritize the control programs. It also is critical to assess and understand the cumulative watershed impacts to quantitatively assess the physical and biological processes and then fashion the watershed-based solutions. Without this understanding, the restoration often treats the symptoms rather than effecting a cure. The tools needed to solve water quality problems in a watershed must be geared to that watershed. The management plans to be developed in the Rouge River must be tailored to address watershed specific problems.

The relationship between developing a TMDL and use of the watershed approach is very important. The TMDL process historically has been used in a very narrow fashion. That is changing and will continue to do so at an increasing rate. USEPA has stressed the linkage between the TMDL program and the use of the watershed approach. USEPA published a final TMDL rule on July 13, 2000. However, Congress added a "rider" to one of their appropriations bills that prohibits EPA from spending FY2000 and FY2001 money to implement this new rule. Therefore, the current TMDL rule remains in effect until 30 days after Congress permits EPA to implement the new rule. TMDLs continue to be developed and completed under the current rule, as required by the 1972 law and many court orders. The EPA has an extensive discussion of the TMDL program on the Agency's web site. The new TMDL regulations can be accessed thorough that site location plus extensive information about the status of the program nationwide. See also Background Information on the Watershed Management Approach and the Tie to the Development of TMDLs.

In summary, a comprehensive watershed management plan and a TMDL can specify the amount of pollution or other stressors that need to be reduced/addressed to meet water quality standards, and the plan/TMDL can allocate pollution control or management responsibilities among sources in a watershed. This appears to be the thrust of the national watershed approach and the TMDL program.

A great deal of work has been accomplished on watershed management plan activities in the Rouge River Watershed because of the work done by the communities and others in addressing the General Storm Water Permit. These efforts were assisted by the Rouge River National Wet Weather Demonstration Project (Rouge Project). The Rouge Project has used that available information to assist in better defining the information needed for the development of a comprehensive watershed management plan. This information can be used elsewhere in the country as a model for comprehensive watershed management plans.

Elements of a Comprehensive Watershed Management Plan
It is important to note there is no one methodology to follow in developing watershed management plans. Instead, there are a series of choices to reach the desired endpoint. The elements discussed below are meant to depict the topics that should be considered in the development of a comprehensive watershed management plan. They are not meant to prescribe a cookbook approach. A watershed plan is a framework for how, where and when management tools will be applied. Innovation is encouraged to reach the goals for restoring/protecting watersheds. Note that the terms "watershed" and "subwatershed" can be used interchangeably. In some cases it may make sense to go to even smaller watersheds, below the subwatershed level, for appropriate watershed management decisions.

The elements listed below can be done in sequence or in parallel because they are interrelated and support each other. There are many opportunities to proceed in parallel with most of the elements that will result in the development of a subwatershed management plan and the restoration of the waterbody in a shorter time. This is especially true when implementing a comprehensive watershed management plan and/or TMDL in phases whereby certain action implementation steps are accomplished, progress assessed and then additional actions undertaken as needed to achieve the desired outcome. Use of an iterative approach to setting goals and implementing actions to achieve standards is an integral part of all of the following elements.

In defining the elements of a watershed management plan it must always be kept in mind the need to address all sources of pollution and all of the other stressors (i.e. lack of habitat, flow variability, etc.) that prevent the attainment of water quality standards.

NOTE: The following list of elements of a comprehensive watershed management plan are for discussion purposes between Wayne County, MDEQ and USEPA. These are meant to be a starting point for those discussions. This s not meant to be a finite list of the elements.

1. Establish the subwatershed baseline of necessary information.
   It is important to gather basic information as a starting point for developing a sound watershed management plan. This will include information about the ecosystem characteristics of the watershed, about possible stakeholders, about technical, human and economic resources, and about related matters, all of which will help guide the development and implementation of the watershed management plan. There must be a review of the available information on the Rouge River. Some of the subwatersheds in the Rouge have more complete data than others. Based on that brief review, for each of the listed items below, the minimum needs to adequately define the baseline of necessary information must be determined.
   
   
   1. Describe the nature and status of the subwatershed ecosystem.
      It is important to note that this description should only be done to the extent required to achieve the purposes of the watershed management plan. Clearly the concept of the "hierarchy approach" and the principle of "inverse proportionality" must be employed here.
      
      The following items should be addressed in the description:
   • The chemical characteristics of the waters based upon historical monitoring data.
   • The biological characteristics of the waters based upon historical monitoring data.
   • The physical characteristics (morphology) of the watershed based upon data.
   • The hydrologic characteristics of the watershed based upon historical data.
   • Information as appropriate on the sediment characteristics in the watershed.
   • The applicable water quality standards and related designated uses for the waters.
   • The delineation of the watershed and subwatershed boundaries.
   • Current adverse impacts on the stream resulting from the current level of environmenal stressors to the river ecosystem.
     
     
   2. Describe the synergistic and antagonistic relationships of the chemical, physical and biological characteristics of the watershed as they impact the achievement of water quality standards and associated designated uses. It is important to note that this will be an iterative analysis as the development of the watershed management plan and/or TMDL progresses.
      
      
   3. Describe other important elements of the watershed important to the development of a watershed management plan such as:
      • Identify possible stakeholders that will be involved in the development and implementation of the watershed management plan.
      • Measure or gauge (by sound estimation) the existing subwatershed land uses and impervious cover due to its direct link to quality of water resources.
      • Assess the local capability to implement needed watershed protection tools by examining existing local programs, regulations/ordinances and staff and other resources.
      • Evaluate the existing mapping resources in the watershed including geographic information systems (GIS) systems.
        
        
2. Define the short-term and long-term goals for the watershed.
   In the Rouge River Watershed, certain overarching goals and associated dates have already been established by MDEQ. Those are to first meet public health protection goals and second to meet water quality standards. These must be addressed in the establishment of goals for the subwatersheds.
   
   
   1. Define the vision and goals for the water quality and designated uses to be achieved in the watershed. The short-term goals must be defined in the context of long-term goals. As noted earlier, the terms "watershed" and "subwatershed" can be used interchangeably. In some cases it may make sense to go to even smaller watersheds, below the subwatershed level, for appropriate watershed management goal setting and decisions.
      
      The goals should, to the greatest extent possible, be measurable environmental end points. They must include achievement of water quality standards and their designated uses. The purpose of identifying short-term and long-term goals is to recognize the phasing of activities that will be needed in order to achieve the end point of meeting water quality standards and designated uses. These interim or short-term goals should reflect the progress in the development and implementation of actions undertaken to meet the long-term goals. These goals should reflect the concepts of "hierarchy approach" and the principle of "inverse proportionality" mentioned above.
      
      It may be appropriate to use surrogate goals to use as measures on the path to achieve the desired water quality goals. These surrogate goals may be management objectives for the subwatershed. For example, "add 150 acres of wetlands in the subwatershed to mitigate flow variability" may be an acceptable surrogate goal for reducing flooding. These surrogate goals must be supported by the appropriate modeling or quantitative rigor.
      
      
   2. Short term and long term goals should be considered for at least the following categories:
      • pollutant/stressor reduction from all sources
      • habitat restoration/enhancement
      • flow control to prevent flow variability and to reduce flooding
      • desired uses of the waters
      • the related chemical, physical and biological endpoints to be achieved.
      
      
3. Identify deviations from goals/target levels.
   
   This step is a characterization of how and the extent to which baseline conditions in the waterbody deviate from the target levels. This characterization should include the identification of deviations from all of the target levels with particular attention being paid to the chemical, physical and biological target levels and their interrelationship. For example, if the long-term goal is the attainment of water quality standards to meet the designated use of a warm water fishery, the physical and biological constraints should be identified if they are factors in the non-attainment of the fishery use. In the Rouge River subwatersheds lack of habitat and the "flashy" nature of the streams will prevent the full achievement of a reliable warm water fishery unless corrective actions are accomplished.
   
   Those factors that directly impact the achievement of the short term and long term goals need to be explained and addressed in the watershed management plan. Again, the hierarchy approach and the principle of inverse proportionality will need to be considered in the identification of the deviations from the goals.
   
   Any data/information gaps must be identified and addressed in the implementation plans discussed later.
   
   
4. Identification of sources of problems.
   
   The purpose of developing the watershed management plan and/or TMDL is to restore the river so as to meet appropriate water quality standards and designated uses. It is very important to clearly identify the responsible sources or categories of sources of problems that are adversely impacting the achievement of the watershed goals, short term and long term. It is also critical to quantify the degree to which each source (or source category) contributes to the problem. In developing the watershed management plan and/or TMDL, it is critical that all categories of sources of problems be identified including physical, chemical and biological. Without this full identification the watershed management plan will not be the holistic plan needed to fulfill the overall goals.
   
   
   1. Point Sources
      
      The following is a list of categories that must be addressed in the identification of the point sources in the Rouge River Watershed that must be considered in the development of the watershed management plan:
      • CSO discharges
      • Storm water runoff
      • SSO discharges
      • Illicit connections
      • On-site systems failures
        
        
   2. Nonpoint Sources
      
      Nonpoint source (NPS) pollution, unlike pollution from point sources, comes from many diffuse sources. Historically, nonpoint sources have not been regulated as comprehensively as point sources and water quality programs for point and nonpoint sources differ in a number of ways. Clearly nonpoint sources cause or contribute to impairments in the Rouge Watershed. Some of the more obvious nonpoint source considerations that must be considered in the development of the watershed management plan are:
      • Excess fertilizers (phosphorus and nitrogen), herbicides, and insecticides from agricultural lands and residential areas
      • Oil, grease, and toxic chemicals from urban runoff
      • Sediment from improperly managed construction sites, crop lands, and eroding streambanks;
      • Bacteria and nutrients from livestock, pet wastes, and faulty septic systems;
      • Atmospheric deposition
        
        
   3. Other Items to be Considered
      
      The above two categories of sources list represents the more classic sources of pollution that would be associated with the development of a watershed management plan and/or TMDL. When combining the development of a watershed management plan and the fulfilling of the TMDL requirements, a broader list of sources of problems must be addressed. The additional "sources " may have impacts on the achievement of the desired goals and therefore must be addressed. A partial list of those other items to consider are:
      • Erosion controls
      • Flow management
      • Changing land use patterns affecting imperviousness
      • Ground water issues
      • Loss of habitat
      • Stream morphology and related impacts on habitat
        
        
5. Allocation of pollution/stressor reduction responsibilities to ensure allocations will lead to the attainment of the watershed management plan goals including water quality standards.
   
   Allocating pollution/stressor reduction responsibilities is the most important and the difficult aspect of the development of a watershed management plan and/or TMDL. Allocation decisions determine implementation responsibilities and their related costs. Many factors may influence allocation decisions such as equity, cost-effectiveness, enforceability, technological feasibility, a logical sequencing of control actions (phasing) to name a few.
   
   It is very important to note that in order for a watershed management plan and/or TMDL to be approvable, the pollution/stressor reduction allocation approach/system must be designed to result in the achievement of water quality standards at some point in time. The details of the pollution/stressor reduction allocation will be directly tied to what is needed to address the mix of physical, chemical and biological stressors that are causing the nonattainment of water quality standards and designated uses. Implementation of the pollution/stressor reduction allocation approach/system may be done in phases or in an iterative fashion with appropriate monitoring/modeling in order to assess progress all of which will be addressed in the details of the implementation plan.
   
   Future growth is a critical item to be considered in the allocation of pollution/stressor reduction responsibilities and the implementation of the watershed management plan. Growth issues are very important to consider when addressing the achievement of short-term goals and their relationship to the established long-term goals.
   
   Modeling will play a critical role in the allocation of pollution/stressor reduction. Again the concept of the hierarchy approach and the principle of inverse proportionality are very important in the development of models. Developing the perfect model is not necessary. An adequate model (versus a perfect model) may well suit the purposes trying to be achieved recognizing the dynamic nature of improvements that will be occurring in the subwatershed as pollution controls are being implemented. Using the approach of "tiered modeling" will save time and money in the development of watershed management plans and/or TMDLs. In other words, because of the nature of the decision to be made, it may be possible to use a less sophisticated model in some cases. As more information is gathered and as implementation steps progress, additional and more sophisticated modeling can be undertaken. The concept of phasing of controls ties directly with using tiered models as progress is being achieved. All of this can be specified in the implementation schedule for the watershed management plan.
   
   In some cases it may be appropriate to have a narrative description of the allocation of pollution/stressor reduction responsibilities versus a quantified load allocation. The key is innovative thinking in making the subwatershed management plan and/or TMDL a viable process for achieving the water quality standards and designated uses.
   
   All of these concepts are already being used in the Rouge River abatement programs established by MDEQ. A good example is the three phases to the CSO control program. Those same principles can apply to the full development and implementation of TMDLs and subwatershed management plans.
   
   
6. Implementation plan for achieving the goals of the watershed management plan and the TMDL.
   
   One of the most important keys to the success of the watershed approach in achieving the requirements of the watershed management plan and/or TMDL is the implementation plan. The implementation plan must specify who will do what by when to achieve the pollution/stressor reduction or other responsibilities identified in the watershed management plan so as to eliminate the use impairments.
   
   The implementation plan should contain certain minimums as summarized below. These are not listed in any special order of importance.
   
   
   1. Describe commitments by the permittees and others to implement the specific actions to achieve the short-term and long-term goals in the following categories of problems(see detailed listing in item 4 above):
      • point sources
      • nonpoint sources
      • other stressors
        
        
   2. Present an implementable plan to achieve public health protection, water quality standards and designated uses in the shortest possible time.
      
      
   3. Delineate specific actions to be taken achieve public health protection, water quality standards and designated uses in the shortest possible time.
      
      
   4. Delineate who will take those actions to be taken achieve public health protection, water quality standards and designated uses in the shortest possible time.
      
      
   5. Delineate a time schedule to accomplish those actions to be taken achieve public health protection, water quality standards and designated uses in the shortest possible time.
      
      
   6. Delineate a priority of actions that reflect the specific water quality problems in a sub-watershed. The priority will be based on public health protection first, achievement of designated uses second and achieving water quality standards third. This implies a phasing of those actions over time.
      
      
   7. Delineate the process for assessing and reporting on progress.
      
      
   8. Delineate the plans for reviewing and updating the subwatershed management plans.
      
      
   9. Delineate the legal authorities under which the control actions will be carried out by the specified implementing agencies/entities.
      
      
   10. Estimate the time required to attain applicable water quality standards given the overall elements of the subwatershed management plan including phasing of controls and management practices.
       
       
7. Define the process for evaluating/assessing the effectiveness of the achievement of the water quality standards and designated uses.
   
   This process should include at least the following components:
   • a plan for assessing whether management measures/control actions and other milestones are being implemented as planned.
   • a plan for assessing whether allocations are sufficient to attain water quality standard.
   • a plan for assessing the improvement in water quality conditions and the progress towards achieving the water quality goals.
   • a plan for assessing the effectiveness of management measures/control actions.
     
     
8. A description of the process for modifying and/or revising the watershed management plan based on the evaluation/assessing of the effectiveness of the plan in achieving water quality standards and designated uses.
   
   This is self-explanatory. Included in this process should be the timetable that will be followed in the periodic revisions.
   
   
9. Description of the long-term water quality monitoring program to support the subwatershed management plan and the TMDL process.
   
   A water quality monitoring program must be designed to be a cost-effective as possible and must be closely tied with the modeling program in order to save on excessive costs. The details of a monitoring program are not described here. There is a huge quantity of literature available on designing an appropriate water quality monitoring program.
   
   Because of the cost of monitoring, it is important to weigh monitoring options against the use of modeling to achieve the most cost effective mix while still obtaining the needed information to support the watershed management plan decisions.
   
   
10. Description of the financial and institutional options and arrangements that will be in place to assist in the success of implementing the subwatershed management plans.
    
    There is no one "right" way to address these important management issues associated with watershed management plans. The best structure depends on the interests of the stakeholders in the watershed, the ability to secure funding, and the complexity of the watershed plan. Choosing the most effective financial and institutional arrangements is one of the more complex decisions the stakeholders will confront. Successful development and implementation of watershed management plans requires a driving force to focus resources of a diverse group of stakeholders. The option chosen must be such that the long-term success of the watershed management plan is enhanced.

Please address all comments and suggestions about the contents of this Web page to rougeweb@co.wayne.mi.us.

The Rouge River National Wet Weather Demonstration Project is funded, in part, by the United States Environmental Protection Agency (EPA) Grants #XP995743-01, -02, -03, -04, -05, -06, -08 and C-264000-01.