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research: bacteria tmdl implementation control strategies of the southeast: recommendations for georgia TMDL Implementation | Outreach & Education | Agriculture | Bacteria Standard Monitoring Solutions for Implementation Measures Efforts are currently underway amongst various groups in Georgia to improve upon volunteer monitoring programs. While the Georgia Adopt-A-Stream is an excellent water quality monitoring and outreach program, it is not designed to provide the level of technical monitoring that is necessary for an adaptive management, proactive approach to TMDL development and implementation. Either strengthening the technical component of the existing Adopt-A-Stream structure or creating another more technical monitoring effort (while leaving outreach and education efforts to the Adopt-A-Stream team) is one solution. An essential element to any monitoring solution is to align monitoring efforts with GAEPD's river basin schedule to supplement efforts already underway by state-led monitoring staff; therefore reducing duplication and increasing efficiency. In this way, volunteer monitors could increase the current labor force working to collect TMDL data. Technical monitoring efforts could also be supplemented by providing modest support funds for graduate students to conduct technical monitoring and further research into cost-effective methods. These recommendations for modifying monitoring efforts would meet overall goals of de-listing streams in a more expeditious manner, illustrate water quality improvements, and highlight situations that require implementation plan revisions. A successful volunteer monitoring model exists in Alabama that could be used as an example for Georgia. Alabama Water Watch (AWW), started by William Deutsch in 1992, provides water quality monitoring data for improvement efforts in Alabama, including TMDL development and implementation. Volunteers receive training in the more technical aspects of water quality monitoring. The program has been so successful, that it has been adopted in other states and countries. AWW could be a useful model for Georgia monitoring efforts because of AWW's success in obtaining quality assurance approval for trainers and officers. The approval of monitoring efforts through the quality assurance process is integral for the use of data in the TMDL development and implementation process. According to federal and state regulations, entities other than the state must have approved Quality Assurance Project Plans (QAPP) if they want their data to be used in assessing TMDL streams, such as listing or de-listing impaired segments. USEPA offers a volunteer monitor's guide to QAPPs at http://www.epa.gov/volunteer/qappcovr.htm. The State of Georgia offers guidance for quality assurance data at http://www.gaepd.org/Documents/techguide_wpb.html (click on "Field Investigation Quality Assurance (Water Quality)") . Some argue that current unapproved monitoring efforts are supplying "trend data." While this data is useful to illustrate trends useful in making management decisions, such as whether or not certain BMP systems are reducing inputs, its use is limited and can not be used in the listing and de-listing of streams. By organizing a large volunteer monitoring effort similar to AWW, the QAPP approval can essentially be distributed throughout the State so that groups are not supplying only trend data, but data that can be efficiently utilized in the TMDL procees. When developing a technical monitoring volunteer effort in Georgia, I suggest using Alabama's Water Watch as a model for obtaining quality assurance approval, and following GAEPD's river basin schedule to make the most out of adaptive management and phased implementation methodologies. Coordination Alabama's Clean Water Partnership (CWP) is an example of stakeholder coordination through a non-governmental initiative. The CWP also provides a neutral forum to discuss and mediate water quality issues because of its independence from one "side" or the other. In many respects, the goals of the CWP align with those of the Georgia River Network (GRN), also a non-governmental organization (NGO). As the Georgia River Network continues to grow and expand their efforts to improve surface water quality in the State, they could possibly integrate some of the successful concepts and methods used by Alabama's CWP. Currently, GRN facilitates efforts and assists in communication between watershed groups (either already in existence or newly formed with help from GRN). With guidance from the CWP's experiences, GRN could consider including coordinators for each basin in GA to assist with TMDL implementation efforts. A GRN river basin coordinator could work in conjunction with outreach coordinators from GAEPD's TMDL implementation program. Currently, Georgia's TMDL implementation program provides a total of four (when all positions are filled) TMDL outreach coordinators to assist with implementation efforts throughout the State. These four outreach coordinators are then divided between the 16 Regional Development Centers (RDCs) who are contracted by GAEPD to develop TMDL implementation plans. In order to see measurable improvements in water quality, we need to increase our state presence of guidance and technical assistance for TMDL implementation. Ownership & Accountability Ownership and accountability must be included as central elements of TMDL implementation plans. The concepts of ownership and accountability refer to assigning responsibility to appropriate entities and stakeholders for the development and/or implementation of actions to meet TMDL plan requirements. Mecklenburg County, which contains the metropolitan area of Charlotte, North Carolina, was able to include these elements. The Surface Water Improvement and Management (SWIM) initiative in Mecklenburg County coordinated the bacteria TMDL implementation plan (or watershed plan) for Sugar, Little Sugar and McAlpine Creeks. Overall, the implementation plan could be used as a template for urban TMDLs in Georgia. In particular, the elements of implementation ownership and accountability were strong and successful. Control strategies and management measures were organized and grouped according to which government entity or group would be responsible. Then each group was assigned ownership or responsibility and asked to write their own implementation action section to encourage communication and accountability. Rusty Rozelle, the program manager, commented that while this increased the length of the project and was frustrating at times; it was well worth it (personal communication 2006). I recommend this implementation plan be reviewed by urban communities in Georgia with similar water quality management issues. Not only can the innovative aspects of BMP implementation be duplicated, but the template can be used to increase accountability and coordination - and water quality. Communication According to research performed by the Georgia bacteria Technical Advisory Group (TAG), a "disconnect" often exists between GAEPD and local stakeholders. For example, the TAG stated that many local governments are frequently unaware of such available assistance. The Center for TMDL and Watershed Studies at VA Tech provides a central source for technical assistance to stakeholders and TMDL implementation project leaders. Through the Initiative for Watershed Excellence: Upper Altamaha Pilot Project, the University of Georgia (UGA) River Basin Center (RBC) can provide similar services through technical assistance and guidance. Therefore contacts made with researchers such as Kevin Brannan at the VA Tech Center could assist in the formation of similar guidance programs in Georgia through the UGA River Basin Center. Virginia also provides the Guidance Manual for Total Maximum Daily Load Implementation Plans. One recurring theme I encountered during my research was the request and need for more specific guidance for TMDL implementation plan development from the regulatory agency. The TMDL Implementation Plan guidance document produced by the State of Virginia's DCR and DEQ could provide an excellent template for a similar material aimed at stakeholders and communities in Georgia. I suggest, of Virginia's two agencies, that Georgia work with DCR because of their focus on NPS TMDLs, which is the greatest issue currently facing Georgia's TMDL program. It should be of particular importance to stay in contact with VADCR because Charlie Lunsford (VADCR) stated they will be revising their TMDL implementation plan guidance soon to include more information about urban TMDL implementation (personal communication 2006). Another benefit of Virginia's guidance manual is that they have been using phased or staged implementation for TMDLs. This would assist Georgia in improving upon its own program. Virginia also uses many different sources of funding at the State and local levels and could provide useful information for future strategies in Georgia. Two components of the VA TMDL implementation plan guidance manual could assist Georgia stakeholders in the inclusion and implementation of appropriate actions and management measures detailed in TMDL implementation plans: "Chapter 6.0: Linking the TMDL to Implementation: Detail of TMDL Analysis (p.18)" and "Table 6.1: BMPs applicable to bacteria (p.27)". "Detail of TMDL Analysis" refers to chapter 6 of the Guidance Manual and covers how to determine the level of effort needed for assessing implementation action needs and what management measures are needed for success. The chapter is divided into sections on the level of analysis needed (and how to identify it) and what resultant steps are needed for implementation. The guidance provided is in-depth and easy to understand and broadly applicable. Important concepts are introduced, such as planning for future impairments. For instance, in various implementation plans written in Virginia, control strategies recommended to reduce bacteria loadings could also reduce other pollutants such as sediment and nutrients that could occur in future TMDLs. Guidance also refers to properly estimating future costs associated with technical and administrative assistance that should be taken into account. One of the most useful aspects of Virginia's implementation guidance chapter, is the table outlining BMPs that can be implemented to specifically reduce inputs of bacteria. In Table 6.1, best management practices include information such as which impairment source (i.e. agriculture or urban) they are best suited for, their efficiency (if available) and average cost. After reviewing many BMP manuals, I have concluded that this table in particular provides a good "overview" of available practices for bacteria abatement in a user-friendly format. The examples and resources referred to are just a sampling of the guidance available in the Virginia manual. The manual has a great deal to offer for the improvement of TMDL implementation in the State of Georgia, and is therefore included as a recommendation of this project. Using a 319 grant, or something of the like, a group like the UGA River Basin Center (or a consortium) could develop an implementation manual for the State of Georgia using Virginia's manual as a template. Under federal and state regulations, outreach and education efforts are required aspects of water quality implementation projects, whether through the NPDES permitting process or TMDL implementation planning. While this should allow for great successes in stakeholder and citizen educational opportunities, the requirement is often glossed over, and quickly checked off of the laundry list of "things to do," resulting in ineffective outreach and unusable tools. Therefore the brochures and pamphlets are found in the trash can of the citizen or the storage closet of the project leader; and often never reach the audience that needs the information or assistance the most. While any effort is better than none at all, implementation efforts will never be successful without a strong, targeted outreach component. A specific component of strong outreach campaigns involves targeting your audience and then "framing" the issue around the factors that are important to them. One project leader (and county extension agent) in South Carolina mentioned that the "usual" forms of outreach (public meetings and media campaigns) did not work with his audience, owners of failing septic systems (Warner 2005). This was partially due to homeowners being generally wary of regulatory agency personnel (Warner 2005). Therefore, the project leader found the best method for communicating with these homeowners was to solicit the help of certified septic contractors to inform individuals that contacted them about the installation and repair 319 project (Warner 2005). By identifying where and how his audience could best be reached, the project leader could effectively reach the population that needed him most (or at least reach some of them). Sometimes this targeting aspect takes significant creativity, such as that involved in the "faith-based" septic outreach project in South Carolina led by Harold Seabrook. Improving outreach campaigns to better serve the audiences intended will assist in the implementation of bacteria TMDLs. Due to the voluntary nature of most NPS control measures, outreach must also contain social mechanisms to encourage implementation actions. One tactic involves creating situations where people essentially feel peer pressure or ownership, which encourages them to self-enforce water quality-friendly control measures and often convince others to do the same. One example of this is creating dog parks to centralize dog owners and then implement BMPs and outreach tools to encourage scooping-of-the-poop for bacteria NPS abatement. Another method is one used in Alabama in which watershed boundary signs are installed to familiarize and connect residents with the watershed they impact. "Stream naming" can also be a useful tool to provide a sense of ownership to a community of its surface waters. Children in particular can take great pride in "naming" the stream that runs through their school yard or neighborhood. Increasing the attention, time and weight given to the impact of education and outreach in TMDL implementation is a central element to measurable water quality improvements. USEPA: Getting In Step: A Guide for Conducting Watershed Outreach Campaigns SC website of info from EPA Getting In Step Outreach CD, includes info on stormwater, pet waste, and other tools
In terms of best management practices to reduce bacteria inputs from agricultural sources, there are three areas in which to focus improvements: innovative BMP systems, technical guidance and assistance from NRCS and county extension agents, and funding cost-share options for producers. The most important of these areas is guidance offered to agricultural producers from NRCS and county extension agents. These agents provide an invaluable service to farmers and are often the best resources for efforts at the state level because of their knowledge of and relationship with the community and agricultural producers. In each state, 319 project leaders and regulatory agency staff commented that these agents were necessary partners for any sort of implementation project involving rural or agricultural communities. Federal support for NRCS technical staff has decreased significantly (Risse, personal communication 2006). Overall, the current Bush administration increased total funding to NRCS, but required that most of the money go to cost-share programs (Risse, personal communication 2006). According to Mark Risse, Georgia is doing the best they can, but it is difficult to give out more money with less people (personal communication 2006). Increasing support at the state level for county extension agents could help with this burden on NRCS agents and essentially improve the allocation and implementation of cost-share funds and producer-oriented support. Options could include workshops, training, and technical support. Watershed tours and BMP demonstration projects are also successful tools for garnering support for installation participation and education. The UGA Cooperative Extension Service is investigating ways to improve upon the current program. The Georgia Agricultural Pollution Prevention Program provides education and technical assistance to the agricultural community through a partnership between the State Pollution Prevention Assistance Division (P2AD) and the UGA Cooperative Extension Service. Cooperative Extension and the UGA River Basin Center's Initiative for Watershed Excellence: Upper Altamaha Pilot Project are working together to pilot the State's first "watershed agent." A watershed agent can focus on water quality issues that extension agents generally do not have the time or mandate to address. Dr. Mark Risse at the UGA Cooperative Extension Service is also organizing and implementing efforts to alleviate the negative impacts of livestock on water quality. In particular, the Equine-A-Syst pilot project shows great potential for success in Georgia. Combining this horse farmer education program with a volunteer mobilization effort like the REINS program in North Carolina could show measurable improvements in water quality on horse farms throughout the State. One of the most important aspects of the program is the use of horse producers as volunteer trainers. This strengthens the relationship between horse producers and extension agents and encourages communication and accountability. Programs such as these can also provide solidarity amongst horse producers, who often do not have the same outlets for meeting other producers (like the Cattlemen's Association) (Risse, personal communication 2006). Continuing to combine management strategies into BMP systems will not only improve water quality, but also the efficiency of the individual best management practices. Based on current literature (Mostaghimi et al. 2002; Thomas 2002; Byers et al. 2005) and reviews of state programs and projects (particularly Clemson University County Extension Agent, Morris Warner in South Carolina, the exclusion and management of grazing livestock away from surface waters will have the greatest impact on the improvement of bacteria impaired streams. These best management practices can include exclusionary fencing, alternative shade sources, and alternative water sources. Kevin Brannan at VA Tech (go to link for VA Tech TMDL Center in VA section) mentioned that oftentimes exclusionary fencing is abandoned after it's damaged in a flood because cost-share monies only cover the original installation and repairs can be quite costly (personal communication 2006). In Byers et al (2005), however, cattle spent less time in riparian areas when alternative sources of shade and water were provided. Therefore, if exclusionary fencing is inappropriate or too costly, providing additional shade and water sources for cattle will still decrease direct deposition of feces into surface waters. Focusing on creative methods for implementing the necessary BMP systems could serve as the most efficient tactic for bacteria TMDL implementation when agricultural land uses and livestock exist. Federal and State-funded cost-share programs are essential for agricultural BMP installation in the private sector. USDA-NRCS cost-share programs contain certain weaknesses. According to Mark Risse with UGA Cooperative Extension Service, these federal programs will only fund on-farm BMP's so there are few opportunities for community-based initiatives and solutions for agricultural programs and producers (personal communication 2006). Virginia has implemented several state-funded cost-share programs to assist with the installation of agricultural best management practices. These funds are combined with federal cost-share programs and implemented through a partnership between VADCR and Soil and Water Conservation Coordinators and their Districts. Virginia has also explored creative options such as a BMP tax credit program and low interest loans. I did not thoroughly investigate whether these financial incentive programs would be feasible in the State of Georgia. However, it does seem like these options could compliment existing efforts such as the Georgia Soil and Water Conservation Commission's Agricultural Conservation Incentive Program and the Ag Lands Program. These current efforts alone are not sufficient, and the development and implementation of a State cost-share program for Georgia is necessary to see increased successes (Risse, personal communication 2006). NRCS EQIP cost-share program Self-determination tool for applicants is located at USDA FSA Continuous Conservation Reserve Program USDA NRCS Conservation Security Program Various recommendations for improving agriculture cost-share programs and efforts in the State were discussed at the Georgia Water Resources Conference in 2001.
Livestock and Poultry Environmental Learning Center Georgia Soil and Water Conservation Commission USDA NRCS USDA Farm Service Agency (FSA) VA BMP Implementation Funding Sources:
Georgia Equine-A-Syst Pilot Project Dr. Mark Risse, an Extension Engineer at UGA's Agricultural Pollution Prevention Program is working with agricultural producers in Georgia to meet water quality goals. The Georgia Agricultural Pollution Prevention Program is a partnership between the State Pollution Prevention Assistance Division (P2AD) and UGA's Cooperative Extension Service which provides education and technical assistance to the agricultural community. Since horses are not considered to provide food or fiber, they are essentially unregulated, as opposed to cattle and other livestock (Risse, personal communication 2006). Horse farms are also therefore ineligible for federal cost-share programs such as those provided by NRCS for installation of best management practices. To complicate matters, according to Risse, many horse farmers in Georgia are essentially "hobby" farmers who are entering the industry after retirement and often have either limited experience with farming of any kind. Equine-A-Syst, modeled after the nationally recognized Farm-A-Syst program, is a self-assessment and education program targeting horse farmers in Georgia (Risse, personal communication 2006). A pilot of the program is currently being implemented by Risse's team in Barrow and Oglethorpe counties with the Oconee Resource Conservation and Development (RC&D) Council. Taking advice from the state of Kentucky, Risse's team is looking at ways to gain eligibility for cost-share monies for horse farmers since horse farming is a top ten commodity in the State. The "Master Equine" program consists of coursework on horse farming with subtle environmental messages throughout. Participants must complete Equine-A-Syst and then work through the application process for NRCS cost-share monies. Thus far, participation response has been overwhelming (Risse, personal communication 2006) Links:
Fecal coliform bacteria are the number one source of impairment to surface waters in the State of Georgia, and many other states. The bacteria Technical Advisory Group (TAG) (link to ga conservancy water quality page - on ga info page of this website) published recommendations in regard to bacteria TMDL development and implementation for the State of Georgia in June 2006. I reference their research in regard to the science of bacteria TMDLs and issues surrounding indicator bacteria and the correlative standard used. Switching from the current fecal coliform (FC) standard to the federally recommended guidance for E. coli may improve protection for Georgia's residents from gastrointestinal illnesses (Radcliffe et al. 2006; USEPA 1986, 2002). Issues exist, however, as to whether or not E. coli underestimates potential health hazards from other, more long-lived bacteria (Carroll, personal communication 2006). Some pathogenic bacteria, such as Enterococcus, from fecal waste have lifetimes in natural waters much longer than E. coli (Carroll, personal communication 2006). In order to decrease public health risks, more investigation into a bacteria standard is needed. While more costly and time-consuming, one solution may be to use a combination of indicator bacteria for Georgia's standard. Learning from the mistakes and successes of other states in the Southeast will assist Georgia through this transition. While the issues and controversies surrounding the indicator bacteria used and resulting standards was not a major focus of this research, I encountered states agencies that are dealing with similar bacteria standard problems. Both Virginia and North Carolina have switched to the E. coli standard from fecal coliform. Virginia, in particular, has conducted a great deal of research on the advantages and disadvantages associated with this new standard. Both Kevin Brannan at VA Tech and Charlie Lunsford with the NPS Program at VADCR commented that the E. coli standard has made the meeting of water quality standards almost impossible throughout the State because the numeric standard is difficult to practically meet (personal communication 2006). Lunsford stated that the new standard is impractical and unrealistic; and they will be reviewing and revising it in the future (personal communication 2006). In particular, Virginia is struggling to meet designated uses due to high levels of E. coli from wildlife deposition and natural background conditions (Brannan, personal communication 2006). These contacts could be consulted by researchers and agency staff members in Georgia. Therefore, it would be in the best interest of the State of Georgia to keep open lines of communication with VADCR and the TMDL and Watershed Studies Center at VA Tech. Brannan, in particular, expressed interest in collaborative work with the University of Georgia (UGA) River Basin Center (personal communication 2006). VA Dept. of Conservation and Recreation, Soil and Water Conservation Programs VA Dept. of Environmental Quality, TMDL homepage VA Tech Center for TMDL and Watershed Studies NC DENR DWQ 319 program A central impediment facing water quality improvements and TMDL implementation is the availability of funding at the State level. Much of this is due to the trust fund system in Georgia where environmental fees are not dedicated. The issue of funding dedication stems from the Georgia Constitution which states that no funds may be "dedicated," except by the Constitution itself (GWC 2005). Therefore the only solution, essentially, is to amend the Georgia Constitution (through placement on the ballot for public vote) to dedicate the funds specifically to the programs enforced by GAEPD (Edwards, personal communication 2006; ACCG 2006). Until this action occurs, current fees are not dedicated and are often redistributed to balance the budget by the General Assembly's appropriations committee (Edwards, personal communication 2006). Georgia has collected fees since the early 1990s from individuals, companies and local governments under environmental programs for the purpose of supporting the administration and enforcement of program activities (GWC 2005). These fees generate enough revenue to fully fund their designated programs, but are instead being used in whole or part to balance the State's general fund (ACCG and GCV 2005). Among the southeastern states, Georgia is the only one not charging some type of NPDES permitting fee to assist in funding program costs. According to data collected by Todd Edwards in 2002, Georgia and Mississippi were the only two out of sixteen Southern states that were not implementing such fees. Wendell Willard (49 th ) of the Georgia General Assembly co-sponsored HB 550 in the 2005 legislative session to provide for fees and change certain provisions of the Georgia Water Quality Control Act. HB 550 provides not only for NPDES permitting fees, but creates a provision whereby government entities would receive fee reductions when fees they had previously paid to environmental trust funds were not appropriated back to the correct department. I recommend that this bill be brought up again and passed to assist in TMDL implementation funding efforts. Problems do still exist in terms of actual appropriation of these funds in light of the constitutional dedication situation. The feasibility of the permitting fee legislation and dedication of said funds should be addressed by the Georgia General Assembly. Each state structures their NPDES fee program differently. Alabama charges NPDES application fees that assist with supporting program staff, but do not directly impact the TMDL program (Hughes, personal communication 2006). North Carolina uses a portion of their permit fees to fund staff positions in water planning and TMDL development (Edwards 2002). South Carolina charges flat, annual permit fees (Edwards 2002; Montebello, personal communication 2006) which support staff positions and program costs for the NPDES state program since 1993 (Montebello, personal communication 2006). According to Mike Montebello at SC DHEC, permit fees are now just seen as a cost of business and are considered an asset to the program (personal communication 2006). Virginia charges permitting fees that last for five years, and fund NPDES permitting administrative costs (Edwards 2002). Research into funding from NPDES permitting fees and trust funds was not a primary piece of this project, but is an important aspect to the future success of TMDL implementation in the State of Georgia. While current information was gained from some of the states studied, it is no way exhaustive and could be an element of future research. North Carolina and Virginia have successfully implemented trust funds to pay for environmental regulatory and enforcement measures. The State of North Carolina supplements funding for water quality improvement projects through the Clean Water Management Trust Fund (CWMTF) as established in 1996 by Article 18, Chapter 113A of the North Carolina General Statutes. The CWMTF issues grants to local governments, state agencies and conservation non-profits for projects specifically addressing water pollution problems, such as TMDL implementation. Alternatively, the State of Virginia utilizes Water Quality Improvement Funds (WQIF), established under the Water Quality Improvement Act (WQIA), to supplement funding for water quality efforts. What is important to note here is that all of our neighboring states are using fees and trust funds to improve water quality. Through our work in the Upper Altamaha watershed of Georgia at the UGA River Basin Center, we are encountering city and county leaders and officials who are concerned with implementing TMDLs not only for water quality reasons, but economic ones. These leaders and communities are asking for help from the State. A revision of limitations on expenditures and encouragement of new revenues, through fees for example, should be undertaken in Georgia. GA trust fund documents
GA HB 550 North Carolina:
Virginia:
BMP Implementation Funding Sources:
Clean Water Act Section 319 NPS grants are a central funding source for TMDL implementation projects, at least for the non-point source pollution component. A common complaint is that the grant application process is onerous and lengthy; and the 40% match requirement poses difficulties. Despite these problems, there are many successful ongoing and planned 319 projects addressing various bacteria NPS sources in Georgia, such as failing septic systems and waste from agricultural livestock practices. To strive towards water quality improvements and successful TMDL implementation in Georgia, the 319 program should also be reviewed and revised as necessary. Through my review of state programs, a trend emerged where state programs spent a sizable portion of their 319 funds in-house to fund water quality positions and programs. While South Carolina strives to spend more 319 money externally, they are currently focusing on a balance between providing support at the State level and then assisting with projects at the community level. Spending a larger percent in-house to fund administrative costs could assist in providing more stakeholder guidance and assistance from the State level. While this recommendation may not be the perfect solution, it could be considered in a reevaluation of the current program. The goal of allocating the majority of 319 funds externally is beneficial for on-the-ground water quality improvements and could be worked towards as alternative state-supported funding solutions come to fruition. There also existed a close connection between the 319 program and TMDL implementation efforts at the State level. Many of SC DHEC's 319 and TMDL staff positions are funded through 319 monies. I highlight South Carolina's program. South Carolina's "watershed managers" not only coordinate TMDL implementation efforts in their respective watershed areas, but also encourage 319 grant proposals to fund implementation projects. Georgia's program is structured similarly and is continuing to work toward goals of aligning the TMDL Implementation Coordinators with 319 program staff will improve efficiency. Another opportunity for improvement exists in the addition of state support for the 319 match requirement. Several smaller communities express concern over applying for 319 monies because of their inability to provide the amount of funds required under the 40 percent match requirement. This could be alleviated by leveraging state funds to assist these communities by reducing their percent match with either a low-interest loan or grant. As will be discussed in the next section on funding, monies could be made available by dedicating trust funds from permitting fees or a similar impact-fee program. Nonpoint Source Program, 319 Clean Water Act Grants 319 Grant Requirements and Forms (which change annually) Alternative Systems: Sub-surface constructed wetlands, like those used in South Carolina , could be a viable option in a situation where conventional septic systems are failing due to poor soil conditions. Comments by several septic experts in Georgia referred to the high maintenance required with a constructed wetland. These comments were made mostly in regard to the vegetative maintenance that was referred to in the interview with South Carolina homeowner and NRCS agent, Gordon Bowdler in Chapter 6. Mr. Bowdler referred to the difficulty involved in maintaining elephant ears, but otherwise stated that overall maintenance was minimal and much less costly than his former conventional septic system. Larry West, a UGA professor in Crop and Soil Sciences, pointed out that when residents are out of town for an extended amount of time there may not be enough wastewater created to keep the sub-surface constructed wetland vegetation alive (personal communication 2006). These comments point again to the concept of site-specificity. Overall, the argument that sub-surface constructed wetlands require too much maintenance is weak. All systems require maintenance. The maintenance required for this alternative system may be more labor-intensive for the homeowner, but seems to be less costly over the long term. This alternative BMP may not be for everybody or every situation, and these maintenance requirements should be kept in mind when choosing which systems to install. The installation of individual on-site wastewater treatment technologies (under 10,000 gallons) is regulated by the Georgia Department of Human Resources Division of Public Health. According to the Manual for On-site Sewage Management Systems , published by the Department of Human Resources, and the "Approved Products" list (see links below), sub-surface constructed wetlands would qualify as an "Experimental On-site Sewage Management System." In this case, experimental systems must apply for temporary approval from the Technical Review Committee for the installation of a limited number of systems to be evaluated over a prescribed period of time (Section G of the On-site Manual). There is a provision allowing for the delegation of approval to the County for subsequent permit approvals once three installations of an experimental system have been permitted (Section G of the On-site Manual). Upon completion of the experimental system installation, the permit holder must prepare final reports on the results and lessons-learned, which, upon review by the Technical Review Committee, can result in statewide approval as an alternative on-site sewage management system. In general, the process is fairly onerous, especially for an individual homeowner. It seems as though most of the applicants for this process are manufacturers, research entities or organizations. Therefore, the best method for introducing individual sub-surface constructed wetlands as an alternative on-site system may be through a research university or other entity that could more easily access funding such as a 319 grant for implementation. While it is beneficial to require such stipulations to protect public health, solutions for alternative technologies should be researched, approved, and implemented in a more expeditious manner. Like many new methods and ideas, this lag-time is resulting from a general lack of will and effort. Especially in the face of failing conventional septic systems, residents should be able to implement innovative technologies and methods if the current system is not meeting their needs. General information and recommendations for GA:
General National information:
Case studies: Because of the opportunity for peer pressure and other social mechanisms to be initiated, I encourage the use and installation of dog parks in public parks where appropriate. Particular consideration should be made to site the park in a location beneficial to water quality such as low grade or slope, significant distance from surface waters, and the use or installation of vegetated buffers. Not only should pet waste receptacles be placed in the park, but also along paths and trails in areas outside of the dog park, particularly along the path leading to the park. The easiest, and potentially cheapest, receptacles to install are simple metal trash cans with a plastic bag retrieval system. Oftentimes, dog park users will bring their own reused plastic grocery bags to refill the systems, therefore reducing the maintenance obligations of the park managers. Because of the number of dog owners visiting the area, signs and information boards can be utilized to not only remind people to scoop-the-poop, but to also educate them on the impact of pet waste on water quality and public health. If the community has also initiated pet waste ordinances, these information kiosks at the dog parks can further educate the public on the pet waste laws and how they could be held accountable. The dog park pilot projects in Virginia, described in Chapter 6, could be used as models for implementation in Georgia. The Upper Roanoke River Roundtable, in particular, is a good model because of the small budget, proving that installation of these best management practices is possible. The Four Mile Run dog park BMP pilot provides a great deal of detailed, replicable information on its project at its website and should be encouraged as a source of information to groups in Georgia. VA: Upper Roanoke River Roundtable (URRR) pet awareness project VA: Four Mile Run bacteria implementation project other pet waste outreach resources:
Atlanta: Clean Water Campaign resources
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