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