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Clean Water Project Tracking & Accounting

Clean water projects target nutrient and sediment pollution to waterbodies and improve water quality over the long term. While measured water quality parameters are the ultimate indicator of progress, it will take time for Vermont’s waters to realize the benefits of clean water projects. To provide incremental measures of accountability, CWIP estimates the pollutant reductions associated with clean water projects installed across state and federal funding programs and regulatory programs in Vermont.

The process of estimating nutrient and sediment reductions associated with clean water projects is referred to as pollutant accounting. To estimate pollutant reductions, CWIP and partners must collect many types of data on the clean water projects implemented (i.e., watershed, land use, storage volume, area treated, etc.), which is referred to as tracking. Tracking and accounting together enable CWIP to estimate the mass of pollutants reduced from projects and monitor progress towards achieving water quality goals, such as Total Maximum Daily Loads (TMDLs).

    Much of the State of Vermont is covered by large TMDLs that require nutrient pollutant reductions (i.e., phosphorus and nitrogen) from nonpoint (rain/snowmelt driven) and point (end-of-pipe) sources. The Lake Champlain and Lake Memphremagog TMDLs both target phosphorus pollution to address cyanobacteria blooms (i.e., blue-green algae), as well as other excess algae and aquatic plant growth. The Long Island Sound TMDL targets the nitrogen pollution which causes low dissolved oxygen in the Sound.

    Tracking & Accounting Methods

    There are a variety of clean water project types across various land use sectors that result in pollutant reductions. CWIP collaborates with numerous state and federal agencies to develop and implement tracking and accounting methodologies for clean water projects.

    Pollution reduction estimates are modeled at the individual clean water project-level, as measuring phosphorus reductions at the project level through water quality monitoring would be cost-prohibitive. Most clean water project pollutant reduction estimates are based on the following:

    1. Estimated total pollutant load from land being treated, prior to treatment by a project or practice. This is based on the area of land draining to the practice or project and the average pollutant loading rate from the land use.

    2. The average annual pollutant reduction performance – referred to as an “efficiency” – of the project type. This is often expressed as a percent of total load reduced and is based on research of project performance relevant to conditions in Vermont.

    The average annual pollutant reduction efficiency for a project is applied to the pollutant load delivered from the land draining to the project to estimate the average annual pollutant reduction. The ability to estimate the pollutant reduction of a project can be limited by lack of data on pollutant loading rates for the land treated and/or lack of information on the performance of a project in treating pollution.

    Standard Operating Procedures

    The Department of Environmental Conservation (DEC) adopted Standard Operating Procedures (SOPs) for tracking and accounting of phosphorous reductions for Agricultural Conservation Practices, Developed Lands Regulatory & Non-Regulatory Clean Water Projects, and Natural Resources Restoration Projects. DEC placed three SOP documents on public notice from March 30, 2022, through May 2, 2022. A public meeting was held on April 15th, 2022. 

    Below are the final SOP documents for tracking and accounting of phosphorous reductions across three major sectors:

    DEC received written comments on the draft SOPs for Developed Lands Regulatory Projects & Non-Regulatory Clean Water Projects and Natural Resource Restoration Projects during the spring 2022 public comment period. A summary of the comments received and the Department’s responses can be found below. No comments were received for the Agricultural Conservation Practices SOPs.

    Technical Resources

    • WID-CWIP Guide to Phosphorus Accounting Eligibility (August 1, 2024). This document provides guidance and criteria for phosphorus reduction accounting associated with clean water projects that are eligible to receive funding under the Clean Water Initiative Program Funding Policy

    Several technical efforts support the development of clean water project tracking and accounting procedures. The following technical resources are being used in the development of forestland tracking and accounting procedures.

    • Forest Land Analysis to Support Implementation of Lake Champlain and Lake Memphremagog Restoration Plan. The University of Vermont Spatial Analysis Laboratory (UVM SAL) recently developed a modeling workflow for mapping forest roads and identifying potentially erosive sections of these features, testing it on pilot sites in the Champlain Valley. In this follow-up project, Watershed Consulting Associates (WCA) and the UVM SAL applied these methods to the entirety of the Champlain and Memphremagog Basins. Task 1 focused on acquisition and processing of high-resolution LiDAR, a remote-sensing data type that is essential to fine-scale analysis of topographic features. Task 2 included development and refinement of a modeling rule set that identified potentially erosive features in forested settings, providing a starting point for subsequent pollution analysis, field investigation, and mitigation. This report summarizes the individual steps in both tasks and the resulting modeling output.

    • Forest Land Accounting Methodology to Estimate Sediment and Phosphorus Reductions. This report summarizes the proposed methods to track and account for phosphorus reductions from forestland practices. This report is the culmination of the collaborative work done by Watershed Consulting Associates, LLC in partnership with an interagency team of experts from the Department of Forests, Parks and Recreation (FPR), and the Department of Environmental Conservation (DEC). Please note this report is still being adapted for the Natural Resources Tracking & Accounting SOP and the methods summarized in this report are not yet final.

    Additional resources for other land use sectors will be posted here when available.

    Clean Water Service Delivery Act 

    The Clean Water Service Delivery Act (Act 76 of 2019) addresses the state’s tracking and accounting in several ways:

    • The state is required to publish methods to estimate phosphorus reductions for all clean water project types in the Lake Champlain and Lake Memphremagog basins by November 1, 2021.

    • The state is required to establish a schedule to publish methods for other (i.e., non-phosphorus) impairments by November 1, 2023. U.S. EPA-supported efforts are underway to coordinate and develop tracking efforts for clean water projects implemented in the Long Island Sound basin.

    • After initial publication of tracking and accounting methods, the state is required to periodically review accounting methods at least every five years to determine the adequacy or accuracy of pollutant reduction values and design lives.

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