Implications of Implementation Priority
for the Neosho Basin
The State views the submission of TMDLs to the EPA as incomplete if some plans for implementation are not incorporated. Such plans will fully recognize the existing efforts underway under the guise of the water quality protection and improvement and will reference current agency programs and authorities, including those of the Kansas Water Plan. Realizing that resources for implementation are finite, a hierarchy of priority among TMDLs for implementation is recommended.
From the perspective of TMDL implementation in the Neosho Basin, priority implies the time periods that state programs and resources are directed at corrective actions to bring about the improvement in attaining water quality standards. TMDLs with High Priority that were developed in 2002 have been implemented since State Fiscal Year 2003. TMDLs that are submitted to EPA in 2008 with High Priority will be implemented from 2009-2016.
As new TMDLs are established for the Neosho Basin, KDHE will establish implementation priorities based on the guidance of the Neosho Basin Advisory Committee.
Guidance for Implementation Programs
The Kansas Water Plan and other programs will be targeted to the priority areas for TMDL implementation with appropriate guidance to the direction of these programs. Targeted implementation of TMDLs will be done at the HUC 11 subwatershed level. Priorities for TMDLs will coincide with HUC 8 priorities for subbasins established under the Unified Watershed Assessment. All of the subbasins within the Neosho Basin are in Category I (watersheds in need of restoration).
Identification of priority segments and subwatersheds will involve assessment of the historic water quality sampling data, consideration of projected population growth in urban and rural areas, population density increases, drainage area, number of confined animal feeding operations and permitted animal units, number of NPDES permitted wastewater facilities, grazing densities, acres of cropland, local geology, potential to generate runoff under varying precipitation conditions, and any additional tributary data on water quality or activities. Each TMDL will identify its priority geographic areas for implementation needs. These areas will be conveyed to agency programs through the Annual Implementation Planning Process of the Kansas Water Plan.
Implementation activities outlined in TMDLs may be incorporated into or facilitate a Watershed Restoration and Protection Strategy (WRAPS) for a specific watershed. Please refer to the KDHE Watershed Management Section or KSWRAPS Web Sites for more information about specific WRAPS projects within this basin.
Data, Monitoring, and Evaluation Needs
As the development of the TMDLs ensues, the Basin Advisory Committee will help identify additional data and monitoring needs relative to evaluating TMDL implementation in the basin. TMDLs of High or Medium Priority should maintain their scheduled frequency of monitoring over 2009-2017, with possible supplemental data collection during infrequent hydrologic conditions, particularly low flows. TMDLs of Low Priority should have appropriate sampling during 2013-2017 for use in evaluating their impaired status in forthcoming Section 303(d) lists. Monitoring during the initial five years of the implementation period, following the approval of a TMDL, will assess the degree of participation in pollution reduction programs and activities. Enhanced monitoring of the quality of the impaired water bodies may be encouraged following the initial five years of monitoring to evaluate achievement of the TMDL goals.