THE VIRGIN ISLANDS NON POINT SOURCE
POLLUTION MANAGEMENT PLAN

 DRAFT 1: Jan 10, 2000

NON POINT SOURCE
9 KEY ELEMENTS OF AN EFFECTIVE TERRITORIAL PROGRAM

Title 12 of the Virgin Islands Code, Section 151, declares that it is the public policy of the Government of the Virgin Islands to "... conserve and control its water resources for the benefit of the inhabitants of the Virgin Islands ...".  Title 12 of the Virgin Islands Code, Section 181, declares that "....it is the public policy of the Virgin Islands to conserve the waters of the Virgin Islands and to protect, maintain and improve the quality thereof for public water supplies, .....".  As a result of these declarations of  policy, the NPS Program of the Department of Planning and Natural Resources (DPNR) is eligible for federal CWA '319(h) funds, which are available for project work to protect and manage the water resources in the Virgin Islands.

The following discussion details the activities to be performed by the Virgin Islands NPS Program which addresses these nine key elements.  Each element is stated in bold and followed by applicable discussion.
   

The Territorial program contains explicit short- and long-term goals, objectives and strategies to protect surface and ground water.

 Long-term Goals

Long-term goals are consistent with the national EPA program vision to achieve and maintain beneficial uses of water.  The long-term goals drive the entire program and are linked to all other short-term goals and program activities (i.e., each long-term goal is linked to and supported by short-term goals).

The NPS Management Plan will be continually updated/ reassessed to link the Section 319 nonpoint source program implementation goals to the accomplishment of other related goals that the Territory established which can help support NPS program implementation.  For example, Section 106 TMDL development and implementation schedules and Section 6217 CZARA implementation schedules pursuant to Coastal Non Point Pollution Source Program.

The Virgin Islands’ Watershed Restoration Action Strategies (WRAS) is being developed subsequent to the Virgin Islands’ Unified Watershed Assessment (UWA) (Attachment A) and in fulfillment with the Clean Water Action Plan Initiative.  The UWA/WRAS outline goals, activities, and milestones to enable the broad variety of public and private-sector stakeholders to understand specifically where and how their participation can help implement an effective program.

A long term action schedule for developing response plans and focusing on 2000-2002 has been developed as part of the WRAS.  The Territory will implement different protection and control strategies, such as increasing the monitoring networks, creating a monitoring and assessment partnership, the implementation of Best Management Practices (BMP’s) for non-point activities, etc,(Attachments B and C).  These strategies will be implemented via Memorandum of Agreements with other agencies.

DPNR has completed and submitted the Comprehensive Land and Water Use Plan (CLWUP) to the Governor for review and approval.  The CLWUP also includes the Virgin Islands Development Law (VIDL).  The CLWUP is currently under review by the Governor and subsequent to his review will be submitted to the Legislature.  In the event that the CLWUP does not receive the Governor’s or Legislative approval, DPNR will be preparing a strategy for achieving approval of the key sections of the proposed VIDL that can be submitted as amendments to the VI Coastal Zone Management Act (VICZMA).  If approved, it will be a strong component in improving land and water use management in the coastal zone.
     

Short-term Goals

Section 319 Non Point Source Program is a management program which provides an assessment of nonpoint pollution and specifies and implements nonpoint source controls.  The program strives to enhance coastal water quality by funding various projects, ranging from information and education programs to highly technical applications of nonpoint source control technology.  Section 6217 Coastal Non Point Pollution Control Program offers enforceable policies that are sufficiently comprehensive and specific to regulate land uses, water uses, and coastal development and is granted the authority to implement the enforceable policies.

A recent survey indicated that a vast majority of residential Onsite Sewage Disposal Systems (OSDS) in the Territory have failed or are failing.  DPNR-Division of Environmental Protection is reviewing the existing OSDS Rules and Regulations to determine if failures of these conventional septic systems are attributable to a lack of adherence to the rules and regulations.  Additionally, the Division will be recommending modifications to the regulations, as necessary, to reduce failures of the traditional OSDS that are attributable to poor design, siting, operation, maintenance, etc, within the next twelve months.

The Division also expects to develop and adopt the Virgin Islands Storm Water Regulations and related Permitting program within the next twelve months.  The Virgin Islands Stormwater Regulation will encompass both Territorial Pollutant Discharge Elimination System permitted sources (point sources)  and other nonpoint sources which may have adverse environmental impacts.  These areas will include stormwater discharges associated with municipal facilities, industrial and construction sites, in the Virgin Islands.
     

The Territory strengthens its working partnerships and linkages to appropriate territorial, and local entities (including conservation districts), private sector groups, citizens groups, and Federal agencies. 

Territory Wide Approach

The Territory uses a variety of formal and informal mechanisms to form and sustain partnerships on a Territory-wide basis.  For example, the Territory has formalized Intergovernmental Agreements with various Federal partners (including the U.S. Geological Survey and the Natural Resource Conservation Service) and local governmental agencies committing these partners to convene regularly to discuss joint development of strategies to address impaired waters, identify funding sources, and to collectively focus their resources on implementing on-the-ground management practices.

 The Territory works in concert with local advisory groups at the community level and in geo-targeted Non Point Source Watershed Management Zones.  These groups incorporate a large variety of private sector and interest groups who can help promote and assure program implementation.   The committee members and their affiliations are as follows:
 

Julie Wright
Water Quality Program Supervisor Cooperative Extension Service University of the Virgin Islands
#2 John Brewers Bay
St. Thomas, VI 00802-9990
Tel:       (340) 693-1082
Fax:      (340) 693-1085
Email: jwright@uvi.edu
 

Dayle Barry
Conservation Data Center
ECC University of the Virgin Islands
#2 John Brewers Bay
St. Thomas, VI 00802-9990
Tel:       (340) 693-1030
Fax:      (340) 693-1025
Email: dbarry@uvi.edu  
   

Mayra Suarez-Velez
V.I. Marine Advisory Service/ECC
University of the Virgin Islands
#2 John Brewers Bay
St. Thomas, VI 00802-9990
Tel:       (340) 693-1392
Fax:      (340) 693-1395
Email: msuarez@uvi.edu
   

Faye Williams
USDA-NRCS
5020 Anchor Way Suite #2
Gallows Bay
Christiansted, VI 00820
Tel: (340) 692-9632, X.101
Fax:      (340) 692-9607
Email: Faye.Williams@vichristia.fsc.usda.gov
   

Rafe Boulon
Chief, Resources Management
V.I. National Park & Biosphere Reserve
P.O. Box 710
St. John, VI 00830
Tel:  (340) 776-6996 x 224
Fax:  (340) 693-9500
Email: rafe boulon@nps.gov
     

Jim Casey
Virgin Islands Coordinator
U.S. Environmental Protection Agency
Caribbean Environmental Protection Division
Federal Building & U.S. Court House
5500 Veterans Drive, Room 142
St. Thomas, VI 00802
Tel:       (340) 714-2333
Fax:      (340) 714-2332
Email: Jim_Casey@www.epa.gov
    

Olasee Davis
Natural Resources Specialist
Cooperative Extension Service
University of the Virgin Islands
RR 2, Box 10,000
Kingshill VI 00850
Tel:       (340) 778-9491
Fax:      (340) 692-4085
Email: odavis@uvi.edu
    

Donna Griffin
Division of Fish and Wildlife
Department of Planning and Natural Resources
6296 Estate Nazareth 101
St. Thomas, VI 00802
Tel:       (340) 775-6762
Fax:      (340) 775-3972
Email: ag420@virgin.usvi.net
    

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The Territory has implemented and will continue to implement many educational outreach activities, including development of school presentations that addresses/discusses NPS issues. The Territory also plans to sponsor conferences and workshops geared towards a wide-range of participants on Territory-wide priorities (i.e., construction, stormwater runoff, onsite disposal, etc.).

Watershed Approach
   
As part of its watershed approach, the Territory plans to address its Category I watersheds, as identified in the UWA/WRAS, through local teams under the leadership of local conservation districts, with Federal and Territorial agencies acting as technical advisors to support local teams in their conservation planning and implementation efforts.

The Territory's watershed approach includes the utilization of community-based advisory committees that recommend how to properly manage the Territory's watersheds and provide direction for local watershed planning and management.

Additionally, the Territory has created watershed advisory groups to assist the Territory in local nonpoint source water quality programs implementation (for example, The Territory provides detailed plans for the groups that have been established to date in the Fish Bay Watershed Management Plan). For each future Watershed Management Plan, the Territory will identify a wide range of specific partners for this effort, including Federal, Territory and Local government representatives, industry, and environmental organizations. In addition to identifying the specific partners that it intends to engage, the Territory also identifies the advisory group's specific roles and responsibilities, with a commitment for the group members to meet on a regular basis.

The Territory program plans will clearly identify the strategy for working with the advisory groups, with a phased watershed plan of activities that involve working with the groups to help identify local sources of NPS pollution, develop locally applicable BMPs, and implement the BMPs. Similar detail is either currently under development or expected to be developed over time for all of the Territory's other Watershed Management Zones.
   

The Territory uses a balanced approach that emphasizes both territorial-wide nonpoint source programs and on-the-ground management of individual watersheds where waters are impaired or threatened.

The Territory intends to target fourteen category I watersheds for intense implementation efforts. These watersheds have impaired water quality; and/or have excellent water quality that the Territory wishes to protect in the face of development and other pressures. Each watershed is described, water quality issues defined, and an action plan identified for additional water quality assessments, watershed modeling and planning, implementation tracking, evaluation, and revision in the WRAS. The watersheds will be addressed (and action plans carried out) through local teams under the leadership of local conservation districts, with Federal and Territorial agencies acting as technical advisors to support local teams in their conservation planning and implementation efforts. The watershed approach will be implemented through WRAS, which include operation and maintenance and environmental indicators to assure that specific quantitative goals are met, with plans for revision when water quality objectives are not met.

Territory Wide Approach
   
The Territorial program includes action plans for each category of NPS pollution that is identified as a most likely source or secondary source in the coastal NPS Assessment Report. Each action plan identifies components such as: related short- and long-term goals, lead and cooperating agencies, potential private sector partners, conservation practices/ BMPs associated with each pollutant, and a specific timeframe for implementation of action plans. Territorial-wide initiatives present in such action plans include informational/ educational program.

The Territory-wide approach addresses significant widespread issues that are prevalent across the Territory (e.g., urban construction activities, sedimentation, etc.). Territory-wide activities are designed to promote broad participation and reach a wide audience (e.g., programs to promote construction BMPs).

Watershed Approach
  
The watershed approach is characterized by four principles: a) well integrated partnerships; b) specific geographic foci; c) action driven by environmental objectives and by strong science and data; and d) coordinated priority setting and integrated solutions.

Balance between the programs will be maintained by priority setting by the NPS Committee comprised of Territorial and Federal agencies with resource management responsibility, which will convene regularly to evaluate the program and determine program needs and priorities, including conservation practices to be demonstrated.

The Territory is integrating its TMDL monitoring and assessment program into its watershed approach for each watershed. Implementation of TMDLs will be achieved through development and implementation of WRAS and the Multi Year Monitoring Strategies (MYMS). The Strategies will specify the necessary pollutant load reductions that need to occur such that loadings will be less than or equal to the TMDL.
   

The Territorial program (a) abates known water quality impairments from nonpoint source pollution and (b) prevents significant threats to water quality from present and future nonpoint source activities. The Territorial UWA identified and prioritize impaired or threatened watersheds.  The WRAS are recommended actions to address those impairments and threats in Category I watersheds.

As stated earlier, the goals of the NPS program include restoration of designated uses of impaired waters and protection of highly valued resource waters.  The goal of the NPS Committee is to develop and carry out action plans that restore or protect such waters by better utilizing the resources of all participating agencies and programs.

The Non Point Source Management Program is designed to address both known and threatened water quality impairments.  For example, the Territory plans to address known impairments by intensifying its NPS management efforts in those watersheds identified as being impaired by construction activities and/or other sources of NPS pollution in the NPS Assessment Report (Attachment D).  In those Category I watersheds, the Territory will implement a wide array of additional BMPs, as well as intensify a newly designed Territory-wide BMP compliance monitoring program to be implemented under section 6217 and CZMA 1996 (Attachment E).  Program plans are also designed to protect the waters of the Territory from sediment resulting from new construction activities by educating and training landowners, construction workers, architects, etc., in the proper planning, application and implementation of BMPs.

The Territory program places a special emphasis on prioritizing §319 resources to address §303(d) - listed water quality impairments attributed to NPS activities.  For example, the Territory facilitates the implementation of §319(h) water quality demonstration projects in those watersheds where §303(d) documented NPS water quality impairments existed.  The WRAS identifies collective resources from Local and Federal partners upon implementing on-the-ground management practices to address specific 303(d) - listed impairments.  These efforts are coordinated through activities such as regular meetings with NPS Committee Members who have on-the-ground knowledge of the watersheds containing 303(d) - listed impairments.
   

The territorial program identifies waters and their watersheds impaired by nonpoint source pollution and identifies important unimpaired waters that are threatened or otherwise at risk.  Further, the territory establishes a process to progressively address these identified waters by conducting more detailed watershed assessments and developing watershed implementation plans, and then by implementing the plans.

 The UWA was a collaborative effort involving relevant parties such as Local government agencies, Federal land management agencies, conservation districts and land conservation departments, nongovernmental and private organizations, other stakeholders and the public.  Based on the UWA, DPNR identified problem watersheds that are most in need of attention beginning in the Fiscal Year 1999-2000 period.  The assessments were based primarily on existing information (e.g., in reports under sections 305(b) (Attachment F), 319(a), 303(d), etc.) tools, and methodologies for evaluating watershed conditions.

Assessments and priorities developed as a result of this process are preliminary and may need to be refined as restoration efforts go forward in future years.  More detailed assessments of conditions in the most critical watersheds requiring restoration has been developed as part of WRAS.  The goals of the NPS program, as described previously, include restoration of designated uses of impaired waters and protection of highly valued resource waters.  The UWA and WRAS processes, aided by the NPS Committee, identifies’ and prioritizes waters impaired or threatened due to nonpoint sources, and recommends actions to address those impairments and threats.  The goal of the NPS Committee is to develop and carry out action plans that restore or protect such waters by better utilizing the resources of all participating agencies and programs.

A number of criteria, in addition to those listed in the UWA, may be used to update/ reprioritize waters that are impaired or threatened by nonpoint source pollution for restoration or protection. Potential criteria currently used include:

• Availability of data;
    

• Classification of water body;
    

• Use support rating;
    

• Geographic scope of problem;
    

• Projected trend of problem (anticipated pollutant loading, land use trends); ecological importance of resource (significant biological resources, rare habitat); workability of solutions (sources known, technology available, agency support, sufficient funding/resources); and
     

• Level of public concern.

Listings of NPS-prioritized water bodies are provided in the UWA.  The WRAS will function as watershed implementation plans.  Action plans may call for additional monitoring to further define the nature of water quality problems.  As part of that effort, the NPS priority status of water bodies in each watershed will be reevaluated based on additional ambient, biomonitoring, and special study monitoring data.

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The territory reviews, upgrades, and implements all program components required by Section 319(b) of the Clean Water Act, and establishes flexible, targeted, and iterative approaches to achieve and maintain beneficial uses of water as expeditiously as practicable. 

The Territorial programs include:

• A mix of water quality-based (e.g., TMDLs) and/or technology-based programs designed to achieve and  maintain beneficial uses of water; and
    

• A mix of regulatory, non-regulatory, financial and technical assistance as needed to achieve and maintain beneficial uses of water as expeditiously as practicable.

(i) Identification of measures: Measures used in the Virgin Islands to control nonpoint sources of pollution have been reviewed and updated in the document “VI Environmental Protection Handbook” and incorporate CZARA Management measures where applicable. The measures are organized by source category.

(ii) Identification of programs: The numerous water quality based and technology based programs in place in the Virgin Islands are organized by source and resource category. Programs cover a broad mix of largely voluntary and educational approaches. Notable exceptions in the form of regulatory programs include:

• Onsite Sewage Disposal Systems (OSDS) regulations, which are technology based through requirements for soil percolation tests;
    

• Urban Stormwater Runoff regulations, which are technology-based through requirements for structural controls on high density development, and which are categorically applied within coastal zones;
     

• Water Supply watershed (wellhead protection) regulations, which use "technology-based' land use restrictions and are categorically applied to zones within water supply watersheds; and
    

• Sedimentation and Erosion Control regulations, which are water quality-based through requirements for 80% reduction of site TSS levels, and which are categorically applied to land-disturbing activities of greater than (1) acre, territorial -wide.

(iii) processes used to coordinate and integrate programs ... : UWA/WRAS development, Coastal NPS Watershed Committee and the Virgin Islands NPS Committee are designed to achieve coordination and integration of the various NPS programs in the territory.

(iv)  federal (non-319), territorial, and local sources of funding.  In addition to continuing base funding to support all programs’ activities described in the following section, numerous sources exist for both discrete and long-term activities.  Federal funds include: USDA Environmental Quality Incentive Program (EQIP.), Clean Vessel Act funded by CZMA; PL-566 Small Watershed Program; EPA 604(b)/2050) water quality planning grants; including the Clean Water.

(v) description of monitoring and other evaluation efforts to help determine program effectiveness: The territorial monitoring program is described separately in the MYMS.  In brief, The Virgin Islands has an extensive network of ambient stations and conducts special surveys, including biological assessments, through the Watershed Management planning process.  DPNR has also funded many researches at the University of the Virgin Islands, using a 319 funds to further evaluate the effects of different landscape features on field-edge runoff before it enters receiving waterways.  These activities allow DPNR to, over larger areas, project future water quality trends and estimate changes that have occurred due to management efforts.
       

The Territory identifies Federal lands and activities that are not managed consistently with Territorial nonpoint source program objectives.  Where appropriate, the Territory seeks EPA assistance to help resolve issues. 

In 1956 Laurance Rockefeller purchased and then deeded large portions of the island of St. John to the U.S. National Park Service. Now almost two-thirds of St. John's 21 square miles lies under its protective care. The park also incorporates 23 sq. km (8.9 sq. Miles) of surrounding marine waters. In 1976 the Virgin Islands National Park & Biosphere Reserve was established nationally under UNESCO's Man and the Biosphere Programme. The "Biosphere Reserves represent superior instructional models of coastal ecosystems in use. They combine core area protection zones with adjacent buffer zones of community cooperation involving innovative, often experimental environmental controls and resource management approaches to research monitoring, conflict resolution, education and co-management". 

In the Territory, the Coastal Zone Management Act provides the legislation for development in the coastal zone (Tier One) and Environmental Assessment Reports are required for all water projects (Minor and Major) and for all Major land projects in tier one. All water projects also require a permit from the U.S. Army Corps of Engineers; a joint DPNR/CZM-Army Corps permit process is in place so that both applications can be handled expeditiously.  Development in Tier Two is enforced through the Environmental Protection Law.   In summary, the DPNR permitting process is comprehensive, incorporating the requirements of the zoning use permit, earth change permit, shoreline, alteration and submerged lands permit. 

Since 1988 the U.S. National Park Service has been collecting monthly water quality data from 30 offshore locations surrounding St. John island. Three of the Park Service measuring sites are located in Lameshur Bay, and one is in Fish Bay.  In order to understand the process of sediment delivery on St. John, the U.S. Geological Survey established two automated suspended sediment pump sampling stations on St. John to compare the sediment yield in a watershed affected by construction activities (Fish Bay) to a watershed in a "pristine" environment (Lameshur Bay).

To ensure federal consistency with the Territorial NPS Management Program, the management  plan includes a two-stage review process.  First, a programmatic review is conducted to determine whether the Federal program process has components that satisfy the Territorial NPS program.  Criteria for the programmatic review include an assessment of whether the Federal program: a) meets the requirements of Section 319; b) meets Territory's water quality standards; c) is consistent with the Territory's implementation schedule and projects; d) identifies BMPs or a BMP process; e) identifies a process of on-site application of BMPs; and f) identifies a process for modification of BMPs.

The second stage of the consistency review includes a review of individual development projects, (e.g., whether the project is consistent with watershed prioritization in the NPS Watershed Management Program, and whether water quality standards and criteria applicable to protecting beneficial uses have been identified).

DPNR also plans to work with Federal land managers by providing them with copies of the Territorial NPS Management Program; developing a compliance checklist; visiting the land manager to review the Territory’s program and the checklist; cooperatively developing action plans for noncomplying lands.

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The Territory manages and implements its nonpoint source program efficiently and effectively,  including necessary  financial  management.

The Territory's NPS Pollution Prevention Program operates pursuant to the 1987 Federal Clean Water Act and the Coastal Zone Management Act Re-authorization and Amendments of 1990 for the purpose of guiding the development and implementation of NPS management efforts to the extent consistent with existing statutory mandates and authority.  These grants are funded through section 319 (h) of the Federal Clean Water Act for projects that implement best management practices (BMPs) or innovative measures and other NPS controls in the 14 Category I watersheds  as identified in the Draft August 1998 Unified Watershed Assessment Report, and for projects that provide education and outreach to critical audiences, both on a watershed and sub watershed basis.  NPS management is a vital aspect of Virgin Islands efforts to improve and protect water quality and water supply on a watershed basis.

The purpose of the 319 funding is 1) to encourage the building of watershed management partnerships within a water management area, a watershed, or a sub watershed; and 2) to implement management practices for NPS control that have been proven to work either in the proposed project area or in another area of similar environmental conditions.  Unified Watershed Assessment Report,  identifies the 14 water watershed management areas.  The DEP is actively involved with beginning watershed management plans for several of the 14 watershed management areas and expects the funded NPS projects to eventually become coordinated with these efforts.

DPNR/DEP has developed guidelines for applicants to use developing proposals for 319 funding.  Management measures are economically achievable measures to reduce NPS pollution.  They reflect the greatest degree of pollutant reduction achievable through the application of the best available nonpoint source control practices, technologies, processes, siting criteria, operating methods or other alternatives (as defined in section 6217(g) of CZARA).  Management measures are the objectives used to achieve an environmental goal.  Management measures should result in delivery reduction of the NPS pollutant(s) to a ground or surface water resource.   Management measures have been broken down into two categories. 

Category I:   Management Practices.

Category II: Education and Outreach to Critical Audiences.

Management Practices

Management practices are employed to achieve a management measure.  A management practices may be physical (e.g. construction) or operational (e.g. operation and maintenance).  Management practices such as source control are the first opportunity in any NPS control effort.  A management practice may be a series of BMPs that in combination achieve the goal of NPS control.

The purpose of Category I is to implement BMPs which have been proven to work whether tested in your project area or in areas of similar environmental conditions elsewhere.  Proposals for Category I must identify the impairment to the watershed/subwatershed and how the project will help mitigate or reduce this impairment or proactively address the prevention of future NPS impairment to the watershed/subwatershed.  A single community seeking a grant will need to think about their role in reducing or preventing NPS pollution within the broader context of a watershed.  The purpose is to encourage partnerships among cooperating entities that all have a "stake" in the environmental improvement of the watershed.   Funding for these projects are encouraged to piggyback with other funding sources or be used to complete an ongoing project.

Education and Outreach to Critical Audiences

Education and Outreach to a Critical Audience are another means to reduce NPS pollution.  The critical audience participation is critical to meet management measure objectives.  The purpose of this category is to provide mechanisms that teach people to implement BMPs or NPS Management Programs.  Public education and outreach has long been recognized as an essential tool for NPS management and control.  Proposals should be comprehensive in the design and implementation approach.

• Identify and target a critical audience(s) within a water region, a watershed management area, or a watershed in accordance with the Unified Watershed Assessment Report or a more territory wide critical audience, e.g., environmental commissions, local government officials, transient summer residents in coastal watersheds, engineers, landscape architects, and homeowners, etc.
     

• Coordinate with existing education and outreach initiatives within the region and/or expand upon an existing successful program.  The success of the initial program must be documented.
      

• Identify partners for the project, including a) others who have a stake in the environmental improvement or well being of the watershed and b) those who can contribute to the project in either cash or in-kind contributions.

DPNR/DEP has established a Financial Management System (FMS) to ensure that the Territory meets its financial reporting obligations.  This system is capable of tracking the amount obligated and encumbered to various contracting agencies and payments due for work in progress.

DPNR/DEP is currently seeking training in the use of the National Grants Reporting and Tracking System (GRTS).  A dedicated staff will be hired for this purpose.  DPNR/DEP will seek assistance from EPA for technical support and hardware/software for GRTS.

As stated previously 319 funds expenditures are tracked using the FMS; the local in-kind contribution is tracked separately by program personnel and reported via monthly reports to the financial staff.  The financial staff will keep a running tally of all in-kind contributions and will record the total amount in the annual Financial Status Report (FSR).

DPNR uses procurement procedures in compliance with local statutes, specifically as codified in the Virgin Islands Code (VIC) Title 31 Chapter 23.  In the past, DPNR has been timely with Performance Partnership Grant (PPG) applications and workplans and has expended grant funds in a timely manner, including executing contracts within a year of PPG award.

Competition for 319 funds is strong, and the NPS Committee review process provides funding to the most worthy projects to maximize environmental benefits.  The strong competition ensures that any leveraging ability proved by 319 funds for other funding sources is maximized employs EPA-approved programmatic and financial accounting systems to ensure that federal and Territorial funds are used consistently with legal obligations.

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The Territory periodically reviews and evaluates its nonpoint source management program using environmental and functional measures of success, and revises its nonpoint source assessment and its management program at least every five years.

Most water management activities in the Virgin Islands fall under VIDPNR-DEP.  The NPS program coordinates activities with the GW, UST and TPDES programs and the Coastal NPS program (§6217 of the Coastal Zone Act Reauthorization Amendments of 1990 (CZARA)) and with agencies outside of VIDPNR including UVI Cooperative Extension Service, the NRCS, USGS, the Department of Public Works (DPW) and the Water and Power Authority (WAPA).

VIDPNR-DEP is striving to involve most pertinent programs in the decision-making processes that will affect overall environmental quality, including ground water and surface water quality.

This work is coordinated indirectly by common environmental goals, direction and focus within each entity and directly, by memoranda of agreements (MOAs) and memoranda of understandings (MOUs) between agencies for specific projects.  Examples of projects include stream storm water quality monitoring (UVI-DPNR), innovative septic system design and testing (UVI-DPNR), farm management plan development and enforcement (Department of Agriculture (DoA-DPNR), GPS Public Water Supply wellhead location (VIRC&D-DPNR).

The Territory incorporates the implementation of CZARA management measures into its short- and long-term program goals.  As is consistent with CZARA, the Territory program plans include a long-term goal of implementing management measures within a 15-year timeframe.  The Territory’s plans also include 5-year implementation plans that are designed to demonstrate progress in achieving full implementation of the management measures.  The 5-year implementation plan describes when, and how program implementation will occur, including mechanisms for tracking and monitoring implementation.  The plan contains interim milestones and benchmarks that will serve as a basis for evaluating progress in achieving program implementation goals.

Evaluations will be based upon a variety of factors that are listed for each category of NPS pollution.  For example, the construction program will be evaluated based on trend analysis of long-term data collected at ambient water quality monitoring stations; analysis of project water quality monitoring when possible; and analysis of watershed monitoring through the implementation program.  The NPS Committee (of Local and Federal agency representatives) will discuss these evaluations annully, and recommend program revisions as appropriate.  The NPS Committee will also meet annually to set priorities for the NPS Management Program for the upcoming year.  The Territory and appropriate cooperating agencies will then work together to develop projects to meet those priorities.  In addition, every five years the NPS Committee will use information available from the Territory's 305(b) water quality inventory report to establish, update the WRAS and identify priority watersheds for the next five years and to evaluate the current program.  New sections will be prepared in response to changing conditions of the Territory's waters as indicated in the Report.

As per the WRAS, the Territory uses a watershed-based management approach, and prepares water quality management plans for category I watersheds.  The plans are prepared by DPNR, established for each of the category I watersheds, consisting of a wide range of stakeholders including Federal, Territorial and Local government representatives, industry groups, environmental groups, and university researchers.  The plans are circulated for public review presented at public meetings in each watershed.  The management plan for a given watershed is completed and will include a detailed schedule for obtaining approval of plans for each watershed.  The plans are then to be evaluated, based on follow-up water quality monitoring, and updated at five-year intervals thereafter.

The Territory is systematically implementing a plan to further develop its technical capabilities.  DPNR is in the process of updating and computerizing its environmental database.  The database will be intergrated into a Territorial Geographic Information System (GIS) to be housed under the umbrella institution Virgin Islands resource Management Cooperative (VIRMC), an affiliation of VIDPNR, UVI, the National Park Service, Island Resources Foundation (IRF) and the Nature Conservancy (TNC).  Water Quality Data, USTs and other pollution hazards will be added to the GIS and the database inventory will serve to increase te capability of managing the natural resources and possible damage to the resources.  Locational data will be derived using GPS equipment to the standards set by EPA Locational Data Policy.

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