Watershed Advisory Groups
Watershed advisory groups (WAGs) are groups of citizens that provide DEQ with local public input and guidance regarding specific watersheds during TMDL development. The WAG provides an opportunity for concerned and involved citizens to be involved with the TMDL process from start to finish. The WAG does not typically write the TMDL document but is an integral part of the process; its input is given great weight in TMDL development and implementation.
Because pollution reduction is often associated with economic, social, and/or cultural impacts, it is important that WAG membership reflect a balanced representation of the interests in the watershed. The individual WAG members come from a broad cross section of the community. The DEQ director appoints WAG members after receiving input from the appropriate basin advisory group.
The size and interests of a WAG vary depending on the community’s level of interest and the complexity of the issues in the watershed. As appropriate, WAG members include representatives from the agriculture, mining, forest products, livestock, and water-based recreation industries; point source dischargers; local government; Native American tribes; environmental groups; and affected land management or regulatory agencies.
A person does not need to be a water quality expert to serve on a WAG. The WAG is not formed for its technical and regulatory expertise but as a source of local information. Individuals who live or work within a subbasin are the experts on that subbasin.
WAGs help DEQ identify local concerns regarding water quality, provide qualitative and quantitative data, and address the relevance of anecdotal information. The legal and technical aspects of a TMDL are largely outside the WAG’s influence and are the responsibility of technical experts from state and federal agencies. These experts write the bulk of the TMDL. It is their job to assess and quantify water quality problems, specify the amount of pollution reduction necessary to meet water quality standards, and develop options to allocate the necessary pollutant limits among the various pollutant sources in the watershed.
The following are key responsibilities of WAGs:
- Advise the TMDL authors on matters of concern to the community.
- Contribute to the education of watershed residents on water quality issues.
- Help identify contributing pollution sources in the watershed.
- Assist in dividing pollution reduction allocations among contributors.
- Recommend specific actions needed to effectively control sources of pollution.
- Help develop and set in motion an implementation plan needed to meet the water quality targets identified in the TMDL.
On average, TMDLs take about two years to develop. During certain periods, the focus may be on data collection, and a WAG may only meet once every few months. However, when critical policy decisions are being made on issues such as load allocations, a WAG may meet more frequently (e.g., several times per month). The WAG's involvement continues through the implementation phase of the TMDL.
To the degree possible, regulatory agencies try to incorporate WAG recommendations into the TMDL. Experience has shown that a TMDL that is supported by the community is far more likely to succeed during implementation than one that is not. In some cases, however, WAG recommendations conflict with regulatory or statutory requirements.
If the WAG disagrees with the TMDL or subbasin assessment, that position and the basis for that position are documented in the public notice of availability of the TMDL for public comment and in the TMDL submission to EPA. The final document also contains the WAG's position and DEQ's response to it.