TMDL Vision Process

1. Introduction

The Long-Term Vision for Assessment, Restoration, and Protection under the Clean Water Act Section 303(d) Program established by EPA and the States proclaims:

"The Clean Water Act Section 303(d) Program provides for effective integration of implementation efforts to restore and protect the nation's aquatic resources, where the nation's waters are assessed, restoration and protection objectives are systematically prioritized, and Total Maximum Daily Loads and alternative approaches are adaptively implemented to achieve water quality goals with the collaboration of States, Federal agencies, tribes, stakeholders, and the public" (emphasis added).

Among the six elemental goals of the Long-Term Vision is "Prioritization":

"For the 2016 integrated reporting cycle and beyond, States review, systematically prioritize, and report priority watersheds or waters for restoration and protection in their biennial integrated reports to facilitate State strategic planning for achieving water quality goals".

The draft guidance for the 2016 Integrated Report encourages States to establish and identify their priorities beyond the traditional 2-year window rendered by the biennial Section 303(d) listing of impaired waters. States have flexibility in how they define their priorities and may use a variety of ways to describe these priorities, which include:

• By geographic units: watersheds, ecoregions, and basins
• By pollutants
• By designated uses

Setting long-term CWA 303(d) priorities from Fiscal Year 2016 to Fiscal Year 2022 affords States an opportunity to strategically focus their efforts and demonstrate progress over time in achieving environmental results. As such, the long-term priorities are not expected to substantially change from Fiscal Year 2016 to Fiscal Year 2022.

Consistent with the new Vision, beginning in 2016, the Integrated Report (IR) submitted by States should include or reference: the State's long-term priorities for the CWA 303(d) program from 2016 to 2022 and the associated rationale used to set these long-term priorities. The rationale should explain how the State arrived at the long-term priorities; and, it should discuss where the State plans to develop future TMDLs, alternative restoration approaches or protection plans and the extent to which they already exist in priority watersheds or water segments.

Kansas Nutrient Reduction Framework

Since 2004, Kansas has chosen to attack nutrients through a strategy of load reduction rather than pursuing numeric criteria. Much of the Kansas strategy has subsequently been endorsed through issuance of a 2011 EPA memorandum outlining the elements of a framework for States to follow in reducing nutrients prior to formally adopting numeric nutrient criteria. The eight elements address prioritization and goal setting, implementing actions, and accounting and reporting of nutrient reduction efforts in the State. The first element calls for "prioritizing watersheds on a statewide basis for nitrogen and phosphorus loading reductions". The three steps under the first element include:

• Use best available information to estimate nutrient loadings on a HUC 8 basis.
• Identify the major watersheds that contribute a substantial portion of nutrient loadings in the State
• Within each major watershed, identify targeted or priority subwatersheds at the HUC 12 scale to implement specific nutrient load reduction activities.

This first element of the nutrient reduction framework became the foundation for Kansas establishing its priorities under the Vision for its 303(d) program. As subsequently described, a number of factors were evaluated for 68 of the 80 HUC 8's in Kansas that had such information with each HUC 8 ranked relative to the others on each factor. A final selection of 16 priority HUC 8s underpinned the beginning of establishing long-term priorities for TMDL development with the 2014 Integrated Report.

A follow-up exercise is underway currently, using EPA Headquarters assistance with the Recovery Potential Tool to veriFiscal Year the placement of the original top 16 HUC 8s as priorities, based on current and potential stressors, water resource value and potential point and non-point implementation success.

2. The Kansas 303(D) Prioritization Process: the Factors

Historic Condition

The first set of factors described the historic ambient condition and relative generation of phosphorus loads within each of the 68 HUC 8s. Those factors include:

• Estimated average incremental P load generated within the HUC 8 in T/yr
• The estimated total P load exiting the HUC 8 (including P loads imported from upstream HUCs in T/yr
• The median TP concentration of all streams within the HUC 8 in mg/l

The loads provided some hydrologic context to the ambient concentrations found in each HUC 8. For example, a HUC 8 with a very high median TP concentration was the Lower Sappa Subbasin in Northwest Kansas. However, the lack of surface flows in that subbasin precluded high loads being generated within the HUC and, hence, low P loads exiting the HUC. Therefore, the inclusion of hydrology tended to push the rankings of loads toward the eastern and central portions of Kansas.

The HUC 8s were ranked from high to low for each of these indicators and scores were assigned to percentile groupings, i.e., Ranks 1 - 7 got 5 points (top 10%); Ranks 8 - 17 got 4 points (11 - 25%); Ranks 18 - 34 got 3 points (26 - 50%); Ranks 35 - 51 got 2 points (51 - 75%); Ranks 52 - 61 got 1 point (76 - 90%) and the lowest seven ranked HUC 8s, Number 's 62 - 68 (bottom 10%) got no points.

Stressors

The next set of factors described the current and probable future stresses that would exacerbate the impacts of phosphorus loading within each HUC 8. These factors included:

• The crop acres in the HUC 8
• The percentage of land area within the HUC 8 that was cropland
• The urban acres in the HUC 8
• The percentage of land area within the HUC 8 that was urban
• The number of stream TP impairments and the number of lake eutrophication impairments present in the HUC 8
• The total design volume of wastewater potentially discharged by the major facilities in the HUC 8
• The % population change between 2000 and 2010 for each county within the HUC 8
• The number of cattle inventoried in each county in 2007 within the HUC 8 These factors were similarly ranked and scored as the historic condition factors.

Relative Value of Water

Several factors were identified that conveyed a sense of value for the surface waters found in each HUC 8. These factors describe:

• The number of Outstanding National Resource Waters (i.e., Tier 3) present in the HUC 8.
• The number of Exceptional State Waters (i.e., Tier 2.5) present in the HUC 8.
• The Priority Riparian Area scores for each HUC 8.
• The presence of a public water supply lake in the HUC 8.
• If public water supplies have a direct point of diversion into any of the streams in the HUC 8 (i.e., public water supplies served by surface waters).
• The influence of the pour point of the HUC 8 on the quality of water seen at the interstate border (At the border, close to the border, distant from the border, or no impact at the border).

Rankings and scores were tabulated for the 68 HUC 8s as with the other factors.

Implementation Potential

The final set of factors dealt with the probability that effective implementation could occur if nutrient TMDLs were established for waters in any given HUC 8. For point source discharges, previous stressor factors involving major NPDES discharges, population growth, and urban land distribution in a HUC 8 also serve as indicators of our ability to control those regulated discharges through wastewater and stormwater NPDES permits. Given the pervasive rural constitution of Kansas watersheds, the key for implementation then lies with the ability of the non-point source control programs at the disposal of the state (i.e., 319, State Water Plan, Farm Bill). Because non-point source control implementation depends heavily on local leadership and management, the factors used for this consideration were tied to the presence and ability of Watershed Restoration and Protection Strategy groups (WRAPS) in certain HUC 8s. Four factors were evaluated for WRAPS in each HUC 8, including:

• Is there an active WRAPS group present in the HUC 8?
• Does the WRAPS group have a history of performing effective implementation on the ground since it formed?
• Has the WRAPS group identified critical HUC 12's?
• Does the WRAPS group have effectiveness monitoring in place to evaluate its efforts?

Results of HUC 8 Prioritization

Kansas decided to concentrate its TMDL development over 2014 to 2022 on the top 25% of HUC 8's among the 68 HUC 8s subject to the ranking and scoring exercise. Essentially 16 HUC 8's were designated as top priority for 303(d) purposes addressing nutrient impairments. These 16 HUC 8's are identified in the table below and displayed in the following map.

Table B1. Top

Figure B1. Top Priority HUC 8's with Nutrient Impairments to be addressed by the 303(d) Program.

These 16 priority HUC 8s became the centerpiece of setting priorities in Kansas' 2014 Integrated Report, including the 303(d) list of impaired waters. The methodology for listing those waters in 2014 included the following provision:

Stream Chemistry Category 5 Priority for TMDL Development

Consistent with Kansas' emerging TMDL Vision Strategy, establishing priorities for TMDL development between 2014 and 2022, certain AUs [Assessment Units] containing streams impaired by total phosphorus in certain HUC 8s will be designated for TMDL development. The targeted HUC 8s and impaired streams intended for TMDLs in 2014 are listed in Table B2.

The HUC 8s and associated impaired streams impacted by phosphorus slated for TMDL development in 2015 are listed in table B3.

Subsequent years will be tied to TMDL development in certain HUC 8s for streams impaired by excessive total phosphorus as seen in Table B4. The year 2017 will be used to catch up on TMDL development in previous AUs that slipped past the end of their designated year and also to develop TMDLs for any emerging issues involving pollutants other than phosphorus. Targeted HUC 8 TMDL development will re-commence in 2018 to 2020 with another catch up period in 2021 prior to the grand evaluation of TMDL impacts, possible revision to existing TMDLs and designation of the next 10 years of priorities in 2022. Adjustments to targeted AUs will be made with the submission of each biennial Integrated Report.

Priority HUC 8's with Nutrient Impairments to be addressed by the 303(d) Program.

Table B2. Targeted HUC8s and impaired streams intended for TMDL development in 2014.

Table B3. Targeted HUC8s and impaired streams intended for TMDL development in 2015.

Table B4. Targeted HUC8s and impaired streams intended for TMDL development in 2016 to 2022.

As can be seen in the first two tables, some discretionary additions were made to the designated HUC 8's subject to TMDL development in 2014 and 2015. Certain HUC 8's were included with the original priority 16 HUC 8's because those additional HUC 8's exert significant influence on the quality seen in the designated HUC 8's. For example, the Lower Cottonwood Subbasin has the city of Emporia located within it and Emporia's wastewater and stormwater discharge near the pour point of that HUC 8 into the Neosho Headwaters HUC 8, which is a priority 16 HUC. It made sense to Kansas to include that lowest portion of the Lower Cottonwood to account for Emporia's influence, even though the ranked factors used to score that HUC 8 came in at a moderate score.

Similarly, the Upper Kansas HUC 8 was not among the priority 16 HUC 8's but it conveys the waters and loads from two upstream priority HUC 8's, the Lower Republican and the Lower Smoky Hill to a downstream priority HUC 8, the Middle Kansas. Hence, it was included to maintain continuity in load transport and relations. Kansas anticipates that other HUC 8's, such as the Gar - Peace Subbasin (11030010) above the Middle Arkansas - Slate priority HUC 8 or the Lower Saline (10260010) and Solomon River (10260015) discharging into the Lower Smoky Hill might be included if their influence is significant.

Additionally, some tributaries to the main stem streams of certain HUC 8's might be subject to TMDL development in subsequent years leading up to 2022. For example, Stranger Creek in the Lower Kansas Subbasin is a major non-point source contributor of phosphorus to the lower Kansas River and will have TMDLs established on it in 2017. Specific timelines were expressed in the actual 2014 303(d) list of impaired waters for certain assessment units.

The 2014 Kansas Integrated Report included text, preliminary outlining the priority and direction of the Kansas Vision for its 303(d) program.

Priorities & Schedules; Introduction of the Kansas TMDL Vision

Since 1999, TMDL development efforts in each of the state's twelve major river basins have attempted to adhere to a five-year rotational schedule. With the emergence of a Kansas TMDL Vision, consistent with the approach supported by EPA's national TMDL Program, significant alteration in scheduling has been made for the years 2014 to 2022. Kansas TMDL Vision is tied to KDHE's Nutrient Reduction Framework and will concentrate on stream phosphorus or nitrate impairments within 16 HUC8's deemed as high priority. The

2014 303(d) list identifies streams in the Neosho Headwaters, Middle Neosho, Spring, and Upper and Lower Walnut HUC8 sub-basins with excessive total phosphorus as slated for TMDL development in 2014.

The list similarly identifies segments of the Kansas River in the Upper, Middle and Lower Kansas sub-basins to have phosphorus TMDLs established in 2015. Streams in six other HUC8's will have stream phosphorus TMDLs developed over 2016 to 2022. As time permits, secondary impairments caused by excessive nutrients including pH, deficient dissolved oxygen or lake eutrophication, may also have TMDLs developed within the priority 16 HUC8 sub-basins. This priority schedule means that no TMDL development will be conducted in other basins of the State, particularly those in western Kansas. Additionally, current plans are that impairments other than nutrients [-driven] will not be addressed during 2014 to 2022.

Relationship with EPA Performance Measures WQ-27 & WQ-28

With the advent in Federal Fiscal Year 2015 of two new performance measures tied to tracking State progress under its Vision-based priority schedule, a clear picture is emerging in Kansas as to what constitutes its universe of priorities slated for TMDL development, the associated baseline of previous accomplished work done in 2012 to 2014 under the guise of the Vision and annual targeted commitments of TMDL production anticipated for each year of the 2015 to 2022 time period.

A subsequent listing within this document will outline the specifics regarding timing of TMDL development for certain stream segments and their supporting HUC 12 sub-watersheds. Those stream segments will be impaired by total phosphorus and/or nitrate and constitute the primary priorities for TMDLs within the 16 priority HUC 8's. These stream segments and associated sub-watersheds represent the assessment units that Kansas will report to EPA in order to populate the WQ-27 measure database.

Other nutrient-based impairments, such as elevated pH or lake eutrophication, in those 16 priority HUC 8's addressed by TMDLs will be accounted for through populating databases supporting WQ-28. Additionally, certain phosphorus or nitrate impairments in other HUC 8's outside the priority 16 that are successfully addressed by TMDLs or, alternatively, technical support for NPDES permitting or 319 watershed planning will also be accounted for in WQ-28. Any emerging phosphorus or nitrate impairments on streams in the priority HUC 8's that arise in the 2016, 2018 or 2020 Integrated Reports for Kansas will be attempted to be addressed with TMDLs in 2021 and credited to WQ-28. Kansas anticipates that the WQ-28 credits will transition over to become part of the baseline for WQ-27 for the time period 2023 to 2032.

3. Alignment of Kansas 303(D) Priorities with EPA National & Regional Priorities

The central theme of Kansas' priorities for its 303(d) program is nutrient reduction in certain surface waters of Central and Eastern Kansas. This priority aligns closely with EPA's priorities on both the national and regional scale. EPA's Fiscal Year 2014-2018 Strategic Plan continues past practice and reaffirms among its goals and objectives:

Goal 2: Protecting America's Waters
Objective 2.2: Protect and Restore Watersheds and Aquatic Ecosystems
Sub-objective 2.2.1: Improve Water Quality on a Watershed Basis

The Strategic Plan is implemented through the Fiscal Year 2014 Final National Water Program Manager Guidance and the Fiscal Year 2015 Final Office of Water Addendum to the Fiscal Year 2014 NPMG. A core priority within the Fiscal Year 2014 NWPMG was "Controlling Nutrient Pollution". Among the anticipated actions to be undertaken by EPA with the States is:

• Work with States to implement the March 2011 memorandum "Working in Partnership with States to address Phosphorus and Nitrogen Pollution through Use of a Framework for State Nutrient Reductions".
• Focus on continuing to work with States to implement the Section 319 program reforms, including updating State NPS Management Plans.
• Continue to work with States to ensure effective permitting of nutrient pollution to protect State WQS.

Secondarily, the efforts of Kansas and its 303(d) program coincide with EPA's priority to, at least indirectly, protect and restore the health of the Gulf of Mexico through, lowered nutrient loads entering the Missouri and Arkansas Rivers, en route to the Mississippi River and the Gulf. One of Region VII's three priorities is protecting and improving water quality across America's greatest watershed, the Missouri-Mississippi Basin.

Among the performance measures associated with the Strategic Plan and Water Program Guidance that are supported by the nutrient-based priorities of Kansas' 303(d) program are:

• WQ-26: Number of states implementing nutrient reduction strategies by (1) setting priorities on a watershed or state-wide basis; (2) establishing nutrient reduction targets, and (3) continuing to make progress (and provide performance milestone information to EPA) on adoption of numeric nutrient criteria for at least one class of waters by no later than 2016. Region VII target = 0.67 for FFY15.
• WQ-SP-10.N11: Number of waterbodies identified in 2002 as not attaining water quality standards where standards are now fully attained. Region VII targets = 467 in FFY15; 456 in FFY14, 443 in FFY13.
• WQ-SP-11: Remove the specific causes of waterbody impairment identified by States in 2002. Region VII targets = 1449 in FFY15, 1417 in FFY14, 1363 in FFY13.
• WQ-SP-12.N11: Improve water quality conditions in impaired watersheds nationwide using the watershed approach. Region VII targets = 14 in FFY15, 13 in FFY14, 11 in FFY13.

Additionally, Kansas' efforts support indirectly the Gulf of Mexico measure that calls for reducing releases of nutrient throughout the Mississippi River Basin to reduce the size of the hypoxic zone in the Gulf. Finally, two performance measures directly tied to the Vision will be unveiled in Fiscal Year 2015 and fully in place for Fiscal Year 2016. The setting of priority areas by Kansas directly aligns with tracking progress and performance defined by these measures.

• WQ-27: Extent of priority areas identified by each state that are addressed by EPA- approved TMDLs or alternative restoration approaches for impaired waters that will achieve water quality standards.
• WQ-28: State-wide extent of activities leading to complete TMDLs or alternative restoration approaches for impaired waters.

4. The Kansas Priorities for TMDL Development from 2014 to 2022

Based on the priority HUC 8's identified as part of the Nutrient Reduction Framework and emphasis on stream phosphorus and nitrate impairments pursuant to the initial identification of the universe and baseline for performance measure WQ-27. The specific assessment unit priorities identified herewith will be used to populate the measure with the associated catchment areas and the schedule of intended TMDL development should translate to annual expectations of commitment between Kansas and EPA. These priorities are memorialized within the 2014 Kansas 303(d) list as either completed TMDLs or listings within the priority 16 HUC 8s.

* Not a priority HUC 8 but exerts significant influence on water quality of priority HUC8

Table B5. TMDL development within the priority 16 HUC 8s prior to 2015.

* Not a priority HUC 8 but exerts significant influence on water quality of priority HUC8

* Not a priority HUC 8 but exerts significant influence on water quality of priority HUC8

Table B6. TMDL Development schedule 2015 to 2022 (plus 2007 nitrate TMDL in the lower KS).

Approach to Changing Priorities

The priorities described in this document and on the 2014 303(d) list represent the anticipated universe of priority waters and issues that will comprise the Kansas Vision effort between now and 2022. However, these priorities and their schedule will subject to two situations: slippage in TMDL development and emerging new priorities. Slippage will be handled by having two turnout periods, in 2017 and 2021, to catch up development of TMDLs underway in previous years. Additionally, 2022may be used, in part, to finalize any late TMDL development prior to reporting out on performance measure WQ-27.

There are four scenarios anticipated to occur that would interrupt the priorities established with this 2015 framework.

First, there may be new stream phosphorus or nitrate listings for streams in the 16 priority HUC 8's that emerge from the 2016, 2018 or 2022 303(d) lists. These new listings will alter the original universe of priority areas and will have TMDLs developed on them in 2012 -2022. Adjustments will be made to the WQ-27 universe to reflect these additional priorities and targets for 2021 and 2022 will correspond to their TMDL development in those years.

Impairments associated with excessive nutrients (pH, deficient DO, stressed biological communities or lake eutrophication) within the 16 priority HUC 8's may have TMDLs developed on them, as time and staffing dictate. Such TMDLs ("priority non-priorities") will have any TMDL established on them in 2022. These additional TMDLs will be accounted for within WQ- 28 as supplemental efforts to the primary priority effort.

Phosphorus or nitrate impairments on streams outside the 16 priority HUC 8's may be addressed by alternative means, either NPDES permitting or implementation of 319 watershed plans (WRAPS). As such, technical aid will be provided by calculating the necessary Wasteload Allocations (WLAs) for point source discharges or Load Allocations for non-point sources without developing a formal TMDL on those impaired waters. These situations will be noted as "5-alt" waters in subsequent 303(d) lists. They shall initially be accounted for within WQ-28, however, when the WQ-27 universe will be reset for 2023 to 2032, these waters will be included in that universe and baseline for the performance measure.

Some impaired waters, not associated with nutrient pollution, may be hoisted upon the Kansas TMDL program for addressing due to some prevailing social, political, environmental, or economic reason. These impairments may be addressed anytime between 2016 - 2022 through an alternative means (e.g., NPDES or 319-WRAPS), without need for a formal TMDL. These "non-priority priority" alternatives will be identified as "5-alt" waters in subsequent 303(d) lists. It may also be possible that Kansas decides to develop a TMDL on these anomalous impairments. If so, they will be developed in 2022 and accounted for within WQ-28.

Kansas will use the Integrated Report to biennially document the status and changes to the universe of priority waters between 2016 and 2020, with a full accounting of all efforts that occurred from 2011 to 2022 in the 2022 Integrated Report.

5. Philosophical Shift in Prioritization Considerations Between 2006 to 2012 & 2014 to 2022

Over the period 1998 to 2006, TMDL development in Kansas was dictated by the terms and schedule of the 1998 Court Decree regarding such development. Under that schedule, all impairments from the 1996 and 1998 303(d) lists had TMDLs developed on a staggered basis, with all such waters in the 12 major river basins having TMDLs established between 1999 and 2006.

After 2006, control over scheduling reverted back to Kansas and a five-year rotation among the 12 river basins was attempted to address priority impairments within those basins. Priorities during this time, prior to the emergence of the National TMDL Vision in 2012, were a function of the value of impaired waters, e.g., large Federal or State lakes afflicted with eutrophication. Many times, Basin Advisory Committees in each of the 12 river basins advised KDHE on those priorities. Additional priority was given to waters of an interstate nature, e.g., the Arkansas River between Colorado and Kansas; or impairments that were initially of concern by emerging watershed groups, e.g., bacteria in streams. After 2010, consideration grew for listings that had been present for some time, approaching the end of 8-13 year window expressed by EPA as the appropriate pace for TMDL development.

With the advent of the National TMDL Vision and Kansas' adoption of a Vision Strategy that focuses on nutrient issues, 303(d) priorities became focused on streams impaired by excessive phosphorus or nitrate. Most major lakes with eutrophication already had TMDLs in place, but streams needed attention because of the prevailing anecdotal evidence that excessive nutrients were a problem, because most major NPDES discharges loaded nutrients into streams, not lakes and because the export of high nutrients from Kansas to downstream locales occurred through stream transport. Coinciding with the State's quest to establish a Nutrient Reduction Framework that would ultimately be implemented through TMDLs, the priorities expressed in this document were established for the time period 2014 - 2022. Some initial work on stream TMDLs had been done and EPA's approval of the Big Creek phosphorus TMDL in 2011 paved the way for TMDL development on the priority stream systems identified in the 2014 303(d) list.

Pace of TMDL development will be dictated by the schedule within this document. Other pollutants will be deferred until 2023 or thereafter. TMDL development will be concentrated in 16 select HUC 8's, located within 6 of the 12 major river basins. No TMDL development is expected in the western third of Kansas, nor is certain eastern basins where population and land use stresses or less prevalent than in the priority areas. An evaluation of the outcomes of this priority TMDL process will occur in 2022, after which, there will be a newly established prioritization scheme for the next 10-year period, 2023 to 2032. Priorities anticipated for that next period will be a function of the progress made on nutrient reductions between now and 2022 and the emergence of environmentally and socially significant impairments that warrant near-term attention on the part of the State.

6. Public Engagement

The interested public has been informed and engaged in the priorities established under the Kansas TMDL Vision since the State undertook its Nutrient Reduction Strategy and Framework over 2004 to 2012. The primary forum for public engagement in the TMDL/303(d) process has always been the 12 Basin Advisory Committees across Kansas. These BAC's were briefed on the changing philosophy on scheduling TMDL development since 2012.

Additionally, the 16 priority HUC 8's have been incorporated into the planning strategy of the Kansas Water Plan and its 12 Basin Plans. These 16 HUC 8's are highlighted as part of the Governor's 50-year Vision for Future Water Supply in Kansas. Implementation decisions regarding fund allocation for non- point source abatement and Federal initiatives such as the National Water Quality Initiative of USDA have utilized the priority HUC 8's and associated priority sub-watersheds to place those funds and programs in order to effect nutrient reduction.

One outcome of the Governor's 50-year Vision is the alteration of the original 12 river basins as the basis for water planning and their replacement as 14 planning regions, which better reflect the blend of surface and ground water resources that dominate certain areas of the state. In keeping with the emerging water planning structure, KDHE has presented how the new planning regions interface with surface waters with nutrient impairments and the priority 16 HUC 8's directing nutrient reduction, including TMDL development. From the following map, one can see that far western areas of Kansas have no significant nutrient issues in their paltry surface water inventory. Nutrients become more prevalent as issues in the central and eastern portion of the state, but there are still areas where the dominant land use of grassland or forest and low population densities dampen the urgency for nutrient control in regions where surface water is abundant.

Because the Kansas 303(d) Vision is tilted toward implementation potential, the primary audiences for where Kansas TMDL priorities are located are the NPDES community and active watershed management groups overseeing non-point source abatement. Numerous discussions and presentations have been made to these groups and their associations to convey the sense of priority that Kansas is taking with nutrients and TMDLs between now and 2022. Major wastewater dischargers and MS4 urban stormwater programs have been fully briefed on these priorities. Interaction between the TMDL program and the 319 program ensures that watershed planning and implementation are coordinated with an eye toward nutrient reductions. Subsequent plan revisions will reflect those priorities and coincide with the priorities presented within this document.

Starting with the 2014 Integrated Report, the 303(d) priorities have been displayed and the rationale behind their enhanced status explained to stakeholders interested in the Kansas environment. The priorities and this document will posted on both the water quality assessment and TMDL development websites of KDHE for public access and review.

Figure B2. Nutrient impaired streams and the Kansas Water Office water planning regions.

7. Conclusion

This prioritization framework represents Kansas' direction for its 303(d) program, scheduling TMDL development to reflect nutrient reduction on priority streams where stresses, value, and opportunities are prevalent. Sufficient flexibility has been designed into the schedule to account for slippage in TMDL development and emergence of additional priorities or issues of concern between now and 2022. The priorities lend themselves to easy translation to populate the new performance measures WQ-27 and WQ-28, allowing for full accounting of TMDL progress leading into the 50th anniversary of the Clean Water Act in 2022. Finally, aggressive adherence to this schedule will expedite Kansas' Nutrient Reduction Framework to move implementation toward real environmental benefits realized through less ambient phosphorus present in stream systems and the accompanying responses in the biological and chemical conditions of those streams more fully supporting their designated uses of aquatic life support, recreation and public water supply, as decreed by Kansas Water Quality Standards.