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Missouri UAA Protocol Update by Ed Galbraith, Barr Engineering, at REGFORM's 2013 Missouri Water Seminar, Sept. 6, 2013
1. Missouri UAA Protocol Update
Ed Galbraith
Barr Engineering
REGFORM Water Seminary
September, 2013
2.
3.
4. UAA Factors 40 CFR 131.10(g)
• 1. Natural Pollutant Sources
• 2. Natural, Ephemeral, Intermittent or Low
Flow Conditions
• 3. Non-Remedial, Human Caused Conditions
• 4. Hydrologic Modifications
• 5. Natural Physical Features
• 6. Substantial and Widespread Economic and
Social Impact
5. The “Outcomes”
1. Warm Water Habitat
2. Exceptional Aquatic Habitat
3. Modified Aquatic Habitat
4. Impairment
5. Remove Use
6. What do we want?
When do we want it?
Permittee stakeholders want an off-ramp that
• Is easy to use and predictable.
• Is possible to understand outcomes
beforehand
• Is not unreasonably expensive
• Is not fraught with uncertainty and risk
Would like a protocol in hand before rule is
effective.
7. What do we want?
When do we want it?
Environmental stakeholders want an on-ramp
that
• Is easy to use and predictable
• Requires minimal level of effort to add
waters
• Can be used by the public
8. Early Comments
• No provisions for flow –based decisions
(permanent flow, permanent pools)
• Criteria do not distinguish between bins
• Some of the guidance documents and
protocols are not applicable to headwater
streams.
• Process for going from “information
gathering” to “decision making” is a bit of
black box.
9. UAA Factors 40 CFR 131.10(g)
• 1. Natural Pollutant Sources
• 2. Natural, Ephemeral, Intermittent or Low
Flow Conditions
• 3. Non-Remedial, Human Caused Conditions
• 4. Hydrologic Modifications
• 5. Natural Physical Features
• 6. Substantial and Widespread Economic and
Social Impact
11. Pop Quiz
Who is best former director of the Water Protection Program?
12. Pop Quiz
Does flow (or lack of flow) enter into the decision process? If so,
what protocol do we use to determine whether the stream has
permanent flow and permanent pools?
13. Pop Quiz
If a segment above the 100K is surveyed and there is no
permanent flow or permanent pools is that an end point?
14. Pop Quiz
If a segment within the 100K is surveyed and there is no
permanent flow or permanent pools, is that an endpoint
15. Pop Quiz
How would respond to this statement: The on ramp for a stream or
lake should be no more than a photograph.
16. Pop Quiz
Should the level of effort to add a stream or remove a stream be:
a. About the same
b. The bar to remove a water should be a lot higher
c. The bar to add a water should be a lot higher
d. None of the above
17. Pop Quiz
If the criteria for the different habitats (warm water, modified,
exceptional) are all the same, what is the incentive for someone
to go through the process?
18. Pop Quiz
In the absence of numeric criteria, how will the data in the UAA
be evaluated?
19. Pop Quiz
Give us a look into the review committee? How will the data be
evaluated once the application is complete?
20. Pop Quiz
What is the air speed velocity of a swallow carrying a coconut?