Accelerating River Restoration Presentation

On the Ground Compliance Audits

Audit Guidance Documents

YouTube Presentations

Curbing Big Six Pollution Sources
Construction Site Sediment Pollution
Improving Stormwater BMP Maintenance

Watershed Group Survey

General Audit Presentation

Preliminary Audit Checklist

Why CEDS Audits Are So Effective in Curbing Pollution

Audit Benefits for Your Organization

What's Covered in a Watershed Audit

Potential Pollution Sources

Wastewater Treatment

Role of Water Quality Monitoring

CEDS is the Best Choice to Audit Your Watershed

Identifying Pollution Usually Missed

Initiating An Audit For Your Watershed

Public Opinion Stops More Pollution Then Legal Action Alone


Training for Watershed Volunteers & Professionals

About CEDS







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Finding the Best for your Case


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Equitable Solutions

ESP: Exposed Soil = Pollution

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Funding the Good Fight

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Property Value

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Special Exceptions & Conditional Uses

Strategy Analysis
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Watershed Audit

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Watershed Audits

If you're concerned about an aquatic resource threat anywhere in the USA then contact CEDS at 410-654-3021 (call-text) or for an initial no-cost discussion of strategy options.

In far too many waterways, poor compliance with pollution prevention laws is the primary factor damaging fishing, swimming, waterfront property value, and aquatic ecosystem health.  Through a CEDS Watershed Audit activities are identified which are releasing more pollution then permitted by clean water laws.  Following are two examples of our audits:

Three new approaches developed by CEDS are utilized in bring these activities swiftly into compliance: On the Ground Compliance Audits, Equitable Solutions and Smart Legal Strategies

CEDS can train volunteer and professional advocates to conduct an Audit or watershed groups can hire CEDS to perform the Audit.  For further detail on engaging CEDS, click Initiating An Audit For Your Watershed.

In the past, identifying and correcting violations has proved challenging for watershed organizations.  The traditional approach entailed expensive monitoring and even more costly court action.  And all too often these efforts produced minimal water quality improvement while alienating elected officials, funders, and others critical to watershed restoration.

The new CEDS Watershed Audit approach has a very high rate of success in swiftly correcting pollution problems.  The Audit is also designed to build alliances with government, the business community, foundations, and others.  The initial Audit can change public opinion in ways that greatly expands support for clean water law enforcement and the other initiatives critical to restoring degraded waterways.  Finally, preventing pollution through an Audit is cheap when compared to restoring a damaged waterway. 

For example, every dollar spent keeping mud on a construction site prevents a minimum of $100 in downstream damages.  In areas where stormwater BMP maintenance is private, it cost $20 in public funds to keep a pound of nitrogen/year out of downstream waters.  If public funds are used to build new BMPs or restoration practices, then the cost is $250 to $900 per pound of nitrogen/year.

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Why CEDS Audits Are So Effective in Curbing Pollution

The heightened success of CEDS Watershed Audits is due to six factors:

  1. We use existing data and quick, low-cost methods in ways that allow us to identify pollution sources others would miss (see Drip-Irrigation example);
  2. We have a nationwide network of PhDs and other professionals which allows us to quickly find reliable solutions for virtually any problem;
  3. We also have a tremendous amount of experience successfully negotiating with the parties responsible for pollution (aka polluter);
  4. We first exhaust all opportunities to work cooperatively with the responsible party to find a mutually satisfactory solution, which we call an Equitable Solution.  Such a solution fully resolves water quality impacts while causing the fewest negative impacts to the responsible party;
  5. If the responsible party fails to cooperate then we begin tactfully informing an ever expanding number of influential people of the refusal to act.  Most responsible parties find that the prospect of a tarnished public image is far more threatening then legal action alone; and
  6. In those rare cases when public opinion fails to bring about full compliance, we utilize the CEDS Smart Legal Strategies approach which triples the likelihood of success in the courts.

Following are examples of the water quality benefits achievable through the CEDS approach:

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How an Audit Will Benefit Your Watershed Organization

With regard to waterway health, the Audit provides three essential benefits. 

First, in most watersheds helping responsible parties comply with clean water laws is the quickest, least expensive option for bringing about substantial water quality improvements;

Second, without full compliance the benefits of expensive restoration practices can be negated, which impedes recovery and makes it far more difficult to convince funders to support your next project; and

Third, the Audit provides advocates with an independent and verifiable source of information regarding compliance levels and other factors critical to watershed restoration.  This independent access to information empowers watershed advocates in ways that lead to far greater success.

A CEDS Audit provides the following additional benefits for watershed organizations:

Also, a CEDS Audit can provide your watershed organization with the ability to be far more successful in curbing pollution releases from sources not covered adequately by current clean water laws, such as stormwater runoff from existing developed areas, cropfields, etc.

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On the Ground Compliance Audits

Many existing pollution sources benefit from some form of treatment intended to reduce the impact to downstream waters.  For example, rural homes are served by septic systems and many suburban-urban impervious surfaces drains to ponds or other stormwater Best Management Practices (BMPs). 

All treatment practices require maintenance to maximize protection of nearby waters.  In far too many instances though maintenance is not carried out frequently or thoroughly enough to keep the practice working at peak efficiency. 

Data regarding compliance is usually limited to that generated by the agencies charged with overseeing maintenance.  If the agency has been starved for the staff and other resources needed to achieve a high degree of maintenance, then their assessment data may be out-of-date or incomplete.  This is why an independent compliance assessments are crucial to preserving and enhancing downstream waters.

Also, the lack of independent compliance assessments prevent watershed advocates from learning of these deficiencies.  Without this awareness advocates never learn of the need to provide elected officials with the public support crucial to keeping compliance at the level needed to preserve and enhance downstream waters.

CEDS developed On the Ground Compliance Audits as a way that allows watershed advocates to independently assess how well aquatic resource protection measures are being maintained.  We've also developed methods for verifying that new development and other project proposals will utilize highly-effective protection measures.

Following are several examples of CEDS audit procedures from our home state (Maryland):

For further detail or audit procedures for other potential pollution sources, contact CEDS at 410-654-3021 or

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Initiating A CEDS Audit for Your Watershed

To explore how an Audit might benefit your watershed contact CEDS at 410-654-3021 or  After learning more about your watershed, the waterways of concern to you, and your priorities, we'll draft a proposal describing an Audit designed to achieve those priorities.  We can then discuss and improve the proposal via a conference call with you and others active in your organization.  Of course there's no charge for these preliminary discussions.  To see an example of an Audit click: Severn River Preliminary Watershed Audit.

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What's Covered in a Watershed Audit

The Audit begins by meeting with you and others active in your watershed organization.  The purpose of this initial meeting is to learn of any particular pollution sources or other factors you see as a priority.  Our goal will then be to achieve your desired end result.  We would also explore questions such as whether you wish to identified as the Audit client.  If not your involvement in the Audit will be kept confidential.

Our most complete, thorough Audit option consists of the following actions:

Background Research
CEDS will begin the process of identifying Potential Pollution Sources by:

Watershed Survey
CEDS will then:

Equitable Solutions To Pollution Problems
After consulting with you to learn which pollution sources you wish to correct first, CEDS will:

When Responsible Parties Refuse To Cooperate
CEDS will:

In most situations responsible parties see that their refusal to cooperate is tarnishing their image.  For most, this is sufficient inducement for the party to begin principled negotiations towards an Equitable Solution.

Assisting Parties Who Lack Resources
Some small towns, institutions, or others may want to do the right thing, but lack the funds or technical expertise to correct a pollution problem.  In these cases the message shifts from one of "why won't the responsible party cooperate" to "let's pool our resources to help the party do the right thing."  The goal then is to generate sufficient public opinion that a source(s) steps forward to provide the necessary funds or expertise.

Additionally, aquatic resource protection is a rapidly developing field.  It's not uncommon that a responsible party is willing to implement an innovative Equitable Solution, but is prevented from doing so by an outmoded law.  In these situations, CEDS can assist your group in encouraging regulatory agencies to allow the solution, at least on an experimental basis. 

Smart Legal Strategies
CEDS has found that parties responsible for a pollution problem will take corrective action about half the time after receiving the initial contact letter.  Another third will do the right thing after getting a call from a local elected official,  State Senator, or other influencer.  And all but a few will eventually correct the problem as the public outcry crescendos.  For the small fraction who still refuse to act responsibly, CEDS has found that our unique Smart Legal Strategies approach will eventually achieve full compliance.

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Role of Water Quality Monitoring

Sampling aquatic resources for bacteria, dissolved oxygen and other physical, chemical or biological parameters is important.  However, monitoring alone is not the shortest route to clean water. 

At most, monitoring reveals existing and past impacts.  It does not prevent future impacts as do Watershed Audits. 

Also, most monitoring is done on nice, sunny days whereas water quality tends to be poorest when rainfall has washed pollutants into a waterway.  Nevertheless, monitoring is an important element in a comprehensive program to preserve and enhance aquatic resource health.  Following are links to water quality monitoring guidance documents:

Again, water quality monitoring is most effective when paired with a Watershed Audit.

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Why Public Opinion Stops More Pollution Then Legal Action Alone

The answer to this question is simple:

The degree to which government enforces clean water laws is directly related to public support and, therefore, prevailing public sentiments.  Similarly, the degree to which responsible parties maintain pollution control measures is a reflection of how noncompliance affects their public image.  A company that gains a reputation for disregarding laws, may find government officials far less accommodating and public opposition more intense the next time they propose an expansion or need a permit for some other activity.  For these reasons, most responsible parties find a well-managed public opinion campaign far more intimidating then just a lawsuit.

The CEDS Equitable Solutions approach capitalizes on this fact by first exhausting all reasonable efforts to work with the party to resolve the problem cooperatively.  Half the time this initial effort brings about a successful resolution.  All but a small fraction of the other parties will eventually resolve the pollution problem as we inform ever larger numbers of influentials and others that we tried to work with the party, but they blew us off.  Eventually the mounting public pressure crosses a threshold where the party decides its in their best interest to do the right thing and correct the pollution.

But this approach ONLY works if efforts to reach an Equitable Solution are exhausted through repeated attempts to open principled negotiations.  In other words, it is vital that you seize the moral high ground from the outset and stay there no matter how others may seek to turn the effort into a brawl.  This can be tricky which is why it helps to have CEDS as an active partner in your first Watershed Audit.  We have been helping watershed groups win these campaigns for more than 40 years.  There are few tactics we haven't confronted and can show you effective counter moves for each.

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Total Maximum Daily Loads, Watershed Implementation Plans & MS4 Permits

Total Maximum Daily Loads (TMDL) are limits placed on the quantity of specific pollutants which can be released to a waterway without jeopardizing fishing, swimming and other beneficial uses.  Watershed Implementation Plans (WIP) set forth the specific actions needed to achieve the TMDL in a watershed.  WIPs are similar to Watershed Restoration Action Strategies and other watershed planning processes.  Areas with a population greater than 100,000 must obtain a Municipal Separate Storm Sewer System (MS4) Permit.  The permit sets forth actions that must be taken to restore local waters to a condition suited to human use.  An MS4 permit may also be required for other areas (see Phase II permit).

Full implementation of a WIP and attaining TMDL limits is, of course, predicated upon a high level of compliance with clean water laws.  The same is true for an MS4 permit.

Unfortunately, the current level of compliance is far from high.  In fact one recent review showed that the 200,000 permitted pollution dischargers in the USA violated permit conditions on average once every two years.  Of course this means that some dischargers caused far more frequent violations while others rarely polluted.  But consider this:

Sensitive aquatic ecosystems will not remain healthy if exposed to pollutional events more frequently than once every three years

CEDS believes that a thorough Audit is a crucial part of the Watershed Implementation Planning process.  Other wise there is insufficient data for estimating the pollution load reduction achieved through existing clean water laws, much less new laws, programs or policies.

The Audit cannot be conducted solely by the enforcement agencies or by others with close ties to the agencies.  It is critical that watershed organizations use the CEDS Audit to, at least, selectively verify the accuracy of enforcement agency data. 

CEDS can also offer another unique and essential service to organizations involved in Watershed Implementation Planning.  As a national organization specializing in helping people and watershed groups preserve aquatic resources, CEDS has a wealth of knowledge with regard to what works.  CEDS can assist you in reviewing a draft WIP to ensure the proposed measures will reliably achieve the TMDL.  For further detail on this service or other aspects of the CEDS Watershed Audit contact us at 410-654-3021 or  

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Training for Watershed Volunteers & Professionals

CEDS strongly encourages watershed organization volunteers and professionals to actively participate in the Audit.  Through this participation your folks will learn how to maintain the higher level of aquatic resource health once the initial CEDS Audit is completed.  In fact, without this ongoing effort one can anticipate that compliance will begin slipping within a couple of years of the Audit.

CEDS can also conduct an intensive training session to show folks how they can conduct the initial Watershed Audit without our active involvement.  To learn more contact CEDS at 410-654-3021 or  

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Why CEDS is the Best Choice to Audit Your Watershed

There are five key reasons why CEDS is the best choice:

  1. CEDS has established a nationwide network of PhDs and other professionals with extensive aquatic resource protection and restoration expertise.  These professionals all have the following in common:
    • they have excellent credentials and are accepted experts in their field;
    • they have the freedom to honestly assess impacts from a pro-environment perspective;
    • they are willing to work on behalf of citizens and nonprofits; and
    • they are open to reducing their rates and other cost-saving steps.
    • Our national network also includes 135 attorneys specializing in representing citizens in land use and environmental cases. 
  2. CEDS does not have the conflict of interest suffered by the consulting companies who would normally conduct a Watershed Audit.  In other words, CEDS does not worry about offending corporations or government agencies by stating the unvarnished truth about pollution sources and what is needed to correct each problem
  3. CEDS has a great deal of experience successfully negotiating with responsible parties, government agencies, and others to win the best watershed protection possible.  And our freedom from conflict of interest allows CEDS to remain firm where others might cave;
  4. Since CEDS specializes in helping citizens and nonprofits nationwide, we have acquired expertise in what works when it comes to fully safeguarding aquatic resource health.  With this expertise we can tell you whether a proposed solution will really protect aquatic resource health or merely sounds good;
  5. Because our clients are all working on a limited budget CEDS has developed a variety of low-cost, yet highly effective methods for quickly identifying and correcting pollution sources.  So your funds go much farther with CEDS.

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Potential Pollution Sources

Following is a listing of the more common potential pollution sources CEDS will identify during a Watershed Audit.  However, most watersheds contain at least a couple of sources not listed below.  The presence of a source does not equal aquatic resource damage.  Instead, CEDS will discretely examine the most directly affected waters for indications of an adverse effect.  We'll also review available monitoring or other compliance data.  If we find cause for concern then we'll consult with you before proceeding with corrective efforts.

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Drip-Irrigation: An Example of How CEDS Identifies Routinely Missed Pollution

Drip-irrigation is a very promising method of managing sewage and other wastewaters.  However, the following example shows that while online compliance data indicated no problems with one facility, further review by CEDS uncovered an appalling pollution problem.  This led to the discovery of a second facility that had been polluting for years without correction.  Both polluting facilities would have been missed without a thorough Watershed Audit.


As shown in the figure above, drip-irrigation releases partially treated wastewater into the soil a couple of feet below grass fields.  Nutrients are taken up by the grass root system.  The grass is then harvested and used in ways that minimize nutrient back into the aquatic environment. 

CEDS was retained by a community of 161 homes to determine if there was any reason to be concerned about a proposal to place a drip-irrigation on an adjoining site slated to be a shopping center.  At first glance we said it looked like good technology but suggested examining a couple of existing, similar facilities just to be certain.

The newest drip-irrigation facility (about three years old) was located nearby.  The online USEPA PCS-ECHO compliance database (same as the NY Times Toxic Waters database) showed this facility had a sterling record.  But this data was based upon pollutant levels in the wastewater after it was treated but before it was discharged into the drip-irrigation fields. 

CEDS toured the plant with the operator then walked the perimeter of the drip-irrigation field.  Everything looked fine until CEDS returned a week later to examine the receiving stream for indications of pollution.  We found the stream to be severely degraded.  We also found that the drip-irrigation fields were now saturated with partially treated (undisinfected) sewage which was flowing into the stream.  The saturation and stream pollution were very serious permit violations.  Again, had we simply reviewed the online data or just toured the plant this gross pollution problem would have been missed.

To determine if this first drip-irrigation site was a fluke or representative of the technology CEDS investigated a second facility.  Online compliance data showed severe problems at this second facility.  In fact, nitrogen releases averaged two-times greater then that allowed by the NPDES discharge permit and this had been going on for eight years since the plant first opened!

Again, the compliance data was based on the treated effluent before it was discharged to the drip-irrigation fields.  So CEDS walked the drip fields and found they were also saturated.  Due to poor treatment essentially raw sewage was flowing from the drip field, down a road and into a nearby stream (see photo below).


Partially Treated Sewage Flowing from a Drip-Irrigation Field

The clean water law violations at both drip-irrigation facilities were extremely serious.  Hundreds of pounds of pollution and disease-causing organisms had been released into nearby waterways.  Most appalling though was the situation at the second plant.

In 2005, three years before CEDS "discovered" the problem, the State had ordered the plant operator to correct the treatment problems.  However, it appears a State inspector had never walked the drip fields and discovered this second serious problem.  As of 2008, plant upgrades had still not occurred.

Initially, CEDS sought to resolve the problems at both plants by working cooperatively with the owners and enforcement agencies.  When this failed to produce correction CEDS initiated a series of actions that focused increasing public attention on the appalling situation.  These actions led to:

Again, the preceding is but one of many examples we could offer for how the methods used in CEDS Watershed Audits will likely uncover substantial pollution sources missed by more routine methods.  For further detail on the drip-irrigation example visit: Equitable Solutions Improves Wastewater Treatment & Protects Threatened Neighborhood.

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