18622_Authority_August_Web

10 The Authority | August 2025 D eveloping p artnerships for Ms4 npDes p erMit C oMplianCe : a C ollaboration s uCCess s tory By Bill Weaver, Lower Paxton Township Authority; Claire Maulhardt, PLA, Capital Region Water; Kathleen Geigley, Susquehanna Township Capital Region Water (CRW) and two upstream neighboring municipalities, Lower Paxton Township (LPT) and Susquehanna Township (ST), collaborated as the Paxton Creek Cooperative, to develop and implement a Joint Pollutant Reduction Plan (JPRP) to reduce sediment from stormwater discharges and stream bank erosion, improve the health of Paxton Creek, Beaver Creek, Spring Creek, and the Chesapeake Bay, and to subsequently achieve compliance with each parties MS4 Individual NDPES Permit. The JPRP includes the Paxton Creek Watershed Total Maximum Daily Load (TMDL) Plan, the Chesapeake Bay Pollution Reduction Plan (PRP), the Wildwood Lake PRP, and the Unnamed Tributary (UNT) Spring Creek. TMDL Background: In 2013, The Pennsylvania Department of Environmental Protection (PADEP) determined that 20 miles of Paxton Creek (approximately 40%) are considered impaired by sediment, with over 86% of the sediment contributed by stream erosion. To address this impairment, the United States Environmental Protection Agency (USEPA) published a Total Maximum Daily Load (TMDL) Report that requires all entities discharging stormwater or combined sewer overflows to Paxton Creek to collectively reduce sediment loads by 35%. As the primary dischargers representing over 98% of the Paxton Creek watershed area, CRW, LPT, and ST proposed, and PADEP agreed, that a single TMDL Strategy for the entire watershed would satisfy permit requirements and be more cost effective than separate initiatives. Paxton Creek has been designated as an impaired stream for sediment and dissolved oxygen, and MS4 sediment waste load reduction allocations have been assigned to several parties including CRW, LPT and ST through the development of a stream TMDL by USEPA/ PADEP. The bulk of the sediment issue was determined to be caused by in-stream erosion and must be addressed by stream bank restoration and stream buffer creation/ restoration. Initial Collaboration: JPRP Preparation including PENNDOT: The Paxton Creek Cooperative started the joint planning in 2015, and in August 2017 the parties entered into an Intergovernmental Cooperation Agreement (ICA) to develop a comprehensive strategy to address water quality requirements and implement the watershed-wide strategy. PennDOT holds a statewide MS4 Permit under which they are encouraged to work with municipalities across the Commonwealth to implement stormwater projects by receiving shared pollutant load reductions. PennDOT owns permitted stormwater systems in the joint planning area which allowed the Cooperative to include PennDOT in the JPRP submitted to the PADEP. CRW, LPT, and ST expanded the partnership further to address requirements for the Chesapeake Bay PRP, TMDL Plan, and PRP to address Wildwood Lake (a sediment impaired impoundment to Paxton Creek) and an UNT to Spring Creek. The Joint Plan was developed to address the watershed pollutant load reduction requirements mandated by USEPA and PADEP. Through successful implementation of the Joint Plan, the objectives to be achieved include: a. short-term sediment load reduction of 10% for the Paxton Creek TMDL;