The early focus of the Rouge Project
was on the control of CSOs in the older urban core portion of the
downstream areas of the Rouge Watershed. As a finite number of point
source CSO discharges could be identified and responsibility for
each defined, the traditional regulatory approach of issuing NPDES
permits mandating corrective action worked relatively well. Additional
monitoring of the river showed that the other sources of pollution
such as storm water runoff, discharges from illicit connections,
and discharges from failed on-site septic systems, needed to be
controlled before full restoration of the river would be achieved
throughout the watershed.
Based upon what was learned, the focus of the Rouge Project became
more holistic to consider the impacts from all sources of pollution
and use impairments in receiving waters by using the watershed management
approach. There is a clear inter-relationship of the pollution sources
within a watershed that demands an inter-related approach to a solution
in order to achieve water quality standards and associated designated
uses within a watershed. A piecemeal approach of focusing only on
sources of pollution or a group of sources will not achieve the
desired results nor will it achieve the acceptance of the residents
of the watershed. The Rouge Project has learned several very important
elements of using the watershed management approach. Those include
the need to: analyze all of the various sources of stressors to
the water quality problems in a watershed-physical, chemical and
biological; establish a hierarchy of pollution sources in a watershed-point
sources and nonpoint sources-based upon the adverse water quality
impacts of those sources; and keep reinforcing, at a watershed level,
the concept of prioritizing the control of those sources and the
other stressors to get desired environmental protection; to recognize
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 to get the maximum environmental
improvement as soon as possible; critically assess the cumulative
watershed impacts to quantitatively assess the physical, chemical
and biological processes and then fashion the watershed-based solutions
to prevent treating the symptoms rather than effecting a cure. The
management plan and tools that are developed must be tailored to
address watershed specific problems.
The use of the watershed approach therefore has emerged as the
most cost-effective and logical approach to water resource management
in the Rouge Watershed and elsewhere.
The challenge for the Rouge Project became to develop innovative
solutions to achieve water quality objectives that may be: 1) more
cost-effective, 2) implemented in a more timely fashion and 3) better
able meet local needs. It has also become clear that water resources
management must have the support of the general public in order
to be effective and to become self-sustaining.
At the heart of the watershed management approach being used in
the Rouge Watershed is the Michigan General Storm Water Permit.
This voluntary permit established the process for developing watershed
management plans to address the control of storm water and other
sources of pollution. This permit evolved from what was being learned
by the Rouge Project.
The seven subwatershed groups (SWAGs) comprised of Rouge River
communities have developed watershed management plans and submitted
them to MDEQ in accordance with the requirements of the Michigan
General Storm Water Permit. The subwatershed management plans do
not require state approval; however, the individual pollution prevention
initiatives emanating from the watershed planning process require
state approval as the activities specified in the initiatives become
permit requirements upon approval. The subwatershed management plans
are now being implemented.
During the latter part of 2001, USEPA's Office of Inspector General
(OIG) conducted a nationwide audit of the national CSO control program.
They interviewed EPA headquarters personnel, three EPA Regions,
eight states, 22 communities and some others. The MDEQ, the Rouge
Project and several Michigan cities were interviewed as part of
the study. The OIG issued their final Evaluation Report on "Wastewater
Management - Controlling and Abating Combined Sewer Overflows"
in August 2002.
The report cites a number of examples of the successes of the Rouge
Project's CSO control program. The following is a quote from
the report about the Rouge Project's CSO control program and
watershed approach being utilized:
"Rouge River Project a Blueprint for Success
The Rouge River National Wet Weather Demonstration in Michigan
is an excellent
example of how utilizing a watershed approach can help to achieve
goals more efficiently. We have previously described in this report
some of the
successful results that have been achieved by this project."
The Rouge Project has provided a unique opportunity for a watershed-wide
approach to restoring and protecting an urban river system by using
a cooperative, locally based approach to pollution control.
View the Assembly of Rouge Communities Web page.