Water Quality Monitoring of the Belle Fourche River

District Involvement in the Process of Setting TMDL

In keeping with the Clean Water Act, the process of setting a Total Maximum Daily Load (TMDL) for the Belle Fourche River and Donkey Creek is underway. The Crook County Natural Resource District has been and remains committed to informing local landowners about the TMDL process as it unfolds. We believe that local input and participation is critical to the success of the TMDL as a means of improving water quality. Through meetings, mailings, newsletters, and newspaper articles, as well as this website, we will try to keep you up to date on the TMDL. There will be a public information meeting in your area soon- please stay tuned, or contact the District for more information!

CCNRD cannot predict how specific the Belle Fourche Watershed TMDL will be, but we feel all landowners should be aware that individual operations may be identified as sources of excess pollution. The environmental consulting firm writing the TMDL will have access to sophisticated mapping techniques and Google-Earth professional software. Google-Earth provides extremely high-definition satellite-based photography. These images can clearly show the number of bales in a haystack or cattle in a pasture as well as degraded stream banks, cattle trails, water tanks, corral locations, etc.

At this point, no one knows exactly what the BFR TMDL may mean for landowners on the river. What we do know is that Wyoming State statute prohibits the introduction of a pollutant into a water body, but Wyoming policy currently acknowledges and has defended "good faith efforts" to implement Best Management Practices to mitigate pollution. This distinction between statute and policy means implementing BMPs in good faith could protect landowners from regulatory action. It means that if you can implement a BMP and limit your pollution contribution, do so and document it!

If you are interested in implementing a BMP, remember the CCNRD Cost-Share Program. We cost-share at a 50% rate, including in-kind contributions (i.e. landowner time and labor). Applications are accepted anytime and are reviewed anonymously. The District currently has $25,000 available for BMP cost-share projects, and we would rather spend it in Crook County than send it back when the grant expires in April 2010! To apply now, click here.

"Background- EPA Policy Changes, 2007"

The Clean Water Act, passed in 1973, calls for TMDLs to be set for all impaired bodies of water in order to improve water quality. In 1996, after high numbers of fecal Coliform were detected, the Belle Fourche River (BFR) was listed on the WDEQ 303(d) list of impaired bodies of water requiring a TMDL. Through a series of meetings with landowners facilitated by CCNRD, the Belle Fourche River Watershed Plan was written and approved. At that time, the approval of a Watershed Plan meant that the BFR was designated as “low priority” for the writing of a TMDL.

The Belle Fourche Watershed 303d listing changed from "low-priority" for TMDL development to "high-priority" for TMDL development in 2007. EPA decided that water bodies with impairments that are a human health hazard, as is E. coli, are "high-priority", regardless of ongoing efforts at the local level, such as the Belle Fourche River Watershed Plan.

Recently, things have begun moving very quickly. By mandate of the EPA, Wyoming DEQ has solicited and reviewed proposals from environmental consulting firms to complete the actual TMDL. CCNRD reviewed the proposals, as well, and was involved in the selection process. A contract has been awarded to TerraTech, and the process of setting the TMDL is underway.

Landowners can still have a voice in this process! Early in the TMDL process, there will be a meeting of all interested stakeholders. This includes landowners, CCNRD, Campbell Co. Conservation District, city officials from Moorcroft, Pine Haven, Hulett, and Gillette, and WDEQ. This meeting will be your opportunity to ask questions, voice concerns, or make comments about the BFR TMDL. It has not yet been scheduled; we will inform you of the time and place when we know.

"What is a TMDL?"

The acronym itself stands for Total Maximum Daily Load. A TMDL is a report, typically 100 or so pages. It is a study of topography, land use, human populations, cattle numbers, wildlife numbers, municipal sewage treatment plants, vegetation, rainfall statistics, run-off patterns etc. A TMDL reports begins by identifying all possible sources of a pollutant (i.e. E. coli). Next, the TMDL assigns percentages to each identified source. We hope the following extremely simplified example will clarify the TMDL process and what it means to a landowner.

Imagine a bucket of water with marbles in it. Let’s say the legal limit of marbles in a quart of water is 50. But, by counting the marbles in a water sample, it is determined that there are 150 marbles in each quart of water. So, the legal limit of marbles is exceeded by 100 marbles, and a TMDL is required.

First, an environmental consulting firm’s report documents the excess “pollution load” (the extra 100 marbles per quart).
Then, the firm considers all the possible sources of marbles in the bucket and assigns responsibility for the excess marbles by percentages. It might look something like this: urban run-off containing pet waste is 25% or 25 marbles; municipal sewage plant sometimes overflows contributing 25% or 25 marbles; improperly installed or aging septic systems are dumping 25% or 25 marble; cattle manure is contributing 25% or 25 marbles.
Finally, the TMDL states that each identified source must reduce its pollutant discharge or “load” by that percentage in order for each quart of water to contain the legal limit of marbles. In the above example, municipalities would have to pass pet-waste laws or institute a collection system for pet waste, the sewage plant would have to increase its capacity, home and landowners would have to replace failing septic systems, and cattle ranchers would have to determine how to reduce the flow of manure to water bodies, each by 25%.

Of course, we’re not dealing with marbles. We are dealing with E. coli bacteria colonies, which are much more difficult to count. In a TMDL, number of bacteria in a watershed may even be measured (by extrapolation) by number of billions of bacteria. Consider these figures from an actual TMDL document for a watershed near Twin Falls, ID:

"Stream Loading by Source -Billions Fecal Coliform per Year (Bfc/year)"

Location	Septic System Load (Bfc/year)	*Unknown Point Source Load (Bfc/year)**	Waste Water Treatment Plant Load (Bfc/year)	Manure Application/ Grazing Cattle (Bfc/year)
Shebang Creek	757	-	-	107,000.000
U. Cottonwood	392	1440	120/829	28,000,000
Stockney Creek	757	5130	-	72,200,00
Red Rock Creek	653	16,370	-	47,500,000
L. Cottonwood	261	-	-	168,000,000
South Fork	183	8640	-	9,610,000
Long Haul Creek	601	-	-	14,400,000
* 0.0, 0.2, 1.0, 2.1, 0.0, 1.3, and 0.0 cattle per creek, respectively

Some TMDL reports go no further than identifying sources of pollutants by percentage. However, some contain “load allocations” which highly specific. Some TMDLs written in farming/ranching areas contain recommendations at the individual land-owner level, mapped by GPS points, for corral relocation, stream bank re-vegetation, catch basins, off-channel water sources, etc.