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vt-lake-champlain-tmdl-phase1-ip-appendices

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vt-lake-champlain-tmdl-phase1-ip-appendices

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendices9-391241656David Mears, CommissionerVermont Department of Environmental Conservation 1 National Life Drive, Main 2 Montpelier, VT 05620-3520Chuck Ross

, SecretaryVermont Agency of Agriculture, Food and Markets 116 State StreetMontpelier, VT 05620-2901Dear Commissioner Mears and Secretary Ross:The pur vt-lake-champlain-tmdl-phase1-ip-appendices

pose of this letter is threefold: to provide comments on the draft "State of Vermont Proposal for a Clean Lake Champlain" (the "Proposal"); to provide

vt-lake-champlain-tmdl-phase1-ip-appendices

the Vermont agencies with a clear understanding of the Environmental Protection Agency's expectations for the development of plans to Implement the r

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendices those reductions are achieved.The State ProposalEPA applauds the substantial efforts the State has made in developing the Proposal. It is broad In sc

ope and ambition, appropriately reflecting the challenge of restoring the health of Lake Champlain. As we have learned from the Scenario Tool, it will vt-lake-champlain-tmdl-phase1-ip-appendices

take an aggressive application of all of the measures In the Proposal to achieve water quality standards. Generally the Proposal lacks the specific d

vt-lake-champlain-tmdl-phase1-ip-appendices

etails of what will be done by when. We appreciate that fleshing out the details is an iterative process and that the public outreach conducted In Dec

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendicesther area that needs to be addressed throughout the Proposal. We suggest that relevant sections in the document include a discussion of how the implem

entation approach will take climate change into account. Climate adaptation and flood resilience should be addressed for each major category of practi vt-lake-champlain-tmdl-phase1-ip-appendices

ces. The report should note the phosphorus increases projected In EPA's climate change analysis, and explain how certain BMP, AAP, AMPToIIFm««1 8M3Z2-

vt-lake-champlain-tmdl-phase1-ip-appendices

TM V^MabU CMon('ll* (MkunnM (O'. Co. won. moor Imeasures can and will be designed to be effecti

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendicesepare and adapt to climate change (e.g., new culvert sizing specifications, etc.) and the additional things the State will be doing moving forward. EP

A's additional comments on many of the programs in the draft Proposal are provided in an attachment.Implementation PlanningWe recognize that the level vt-lake-champlain-tmdl-phase1-ip-appendices

of detail necessary for implementation planning will take time to develop. The following are EPA's expectations divided into distinct planning phases

vt-lake-champlain-tmdl-phase1-ip-appendices

. For the first phase EPA expects the state agencies to revise the Proposal and provide final policy commitments in a basin-wide scale implementation

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendices control measures that will be implemented to achieve the nonpoint source target loads. EPA expects the Phase I Plan to identify a schedule for accomp

lishing reductions including dates for enhancing programs and implementing key actions to achieve these reductions, with all such actions to be implem vt-lake-champlain-tmdl-phase1-ip-appendices

ented as soon as possible and by no later than a date to be discussed further. These actions include, but are not limited to, adopting new regulatory

vt-lake-champlain-tmdl-phase1-ip-appendices

authorities, improving compliance with existing regulations, and securing additional resources for personnel, grant or cost-share programs. Ideally, E

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendicesf the programs identified in the Proposal is described as applicable across the Vermont portion of the Lake Champlain basin. For each of those program

s, EPA expects that the State will identify and commit to implement specific pollutant reduction controls and actions in successive two-year milestone vt-lake-champlain-tmdl-phase1-ip-appendices

s. We anticipate that some programs can be implemented quickly while others will need to be developed. For those items that depend on new funding, ple

vt-lake-champlain-tmdl-phase1-ip-appendices

ase prioritize actions into items that will be funded in the first two years, the next two years, and so on. EPA expects that the Phase I Plan will be

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendicesear preference to retain some flexibility in the TMDL's Waste Load Allocation (for point sources). As noted in my October 23, 2013 letter to Commissio

ner Mears, under these conditions in order for the TMDL to be issued consistent with EPA's regulations, it must provide reasonable assurances that the vt-lake-champlain-tmdl-phase1-ip-appendices

nonpoint source control measures will achieve expected load reductions. A satisfactory Phase I Plan and associated commitment letter will provide rea

vt-lake-champlain-tmdl-phase1-ip-appendices

sonable assurances.After the TMDL has been finalized later this year, EPA expects the State to develop sub-basin implementation plans (Phase II Plans/

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendicestemporal targeting of phosphorus loads to a finer scale will help local decision-makers (e.g., municipal governments, conservation districts, watershe

d associations) better understand thecontribution to and responsibilities for reducing pollutant loads. EPA expects the State to update these basin pl vt-lake-champlain-tmdl-phase1-ip-appendices

ans every five years, consistent with Vermont's current basin planning process, to take advantage of the latest information on phosphorus sources and

vt-lake-champlain-tmdl-phase1-ip-appendices

control options applicable to each watershed. Additional suggestions regarding the Tactical Basin Plans are included in the attachment.Accountability

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendicesress toward fulfilling the pollution reduction targets identified in the TMDL. EPA expects that the State will identify and commit to implement specif

ic pollutant reduction controls and actions in each of the successive two-year milestone periods included in the Plans. Prior to the start of each mil vt-lake-champlain-tmdl-phase1-ip-appendices

estone period, EPA will evaluate whether the actions identified for that period arc sufficient to achieve the pollutant reduction specified for the en

vt-lake-champlain-tmdl-phase1-ip-appendices

d of that two-year period, and whether the State has fulfilled the commitments identified in the previous period- EPA expects that the successive Plan

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendiceshat load reductions will be achieved, and more detailed and transparent reporting to the public. EPA expects this accountability framework, including

development of the Phase I Plans prior to the establishment of the TMDl and the State's commitment to produce detailed Phase II Plans and adopt two-ye vt-lake-champlain-tmdl-phase1-ip-appendices

ar milestones, will strengthen the assurance that the TMDL point and nonpoint source allocations can and will be achieved and maintained.E-PA-Commitme

vt-lake-champlain-tmdl-phase1-ip-appendices

ntsEPA will continue to work in close collaboration with your agencies over the coming months as we develop the draft Waste Load and Load Allocations.

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendices. If the Phase I Plan does not meet the expectations outlined above, EPA may take any of a number of actions. As noted in my October 2 2 03 letter, li

kely options may include, but are not limited to setting Waste Load Allocations that would push Waste Water Treatment Plant discharges to the limit of vt-lake-champlain-tmdl-phase1-ip-appendices

available technology and require offsets for the plants' remaining phosphorus loads, and expansion of permit coverage to bring more sources under dir

vt-lake-champlain-tmdl-phase1-ip-appendices

ect regulatory control (eg., expand MS4 coverage, use Residual Designation Authority to capture currently unregulated point source stormwater discharg

APPENDICESAPPENDIX A - EPA JANUARY 17, 2014 LETTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 16 POST OFFICE SQUARE. SUITE 100BOSTON MA 02109

vt-lake-champlain-tmdl-phase1-ip-appendiceshosphorus reductions, EPA may take any of a number of actions including, but not limited to, designating additional sources to be subject to NPDES per

mits.EPA recognizes and applauds the substantial efforts the State is proposing to take to enhance program capacity and meet the necessary phosphorus vt-lake-champlain-tmdl-phase1-ip-appendices

reduction targets. We look forward to continuing to work with you to achieve a clean Lake Champlain.Sincerely,Stephen s. PerkinsOffice of Ecosystem Pr

vt-lake-champlain-tmdl-phase1-ip-appendices

otectionAttachment

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