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NACWA Priority Issues - Total Maximum Daily Loads Print E-mail

NACWA supports the U.S. Environmental Protection Agency’s (EPA) efforts to revise the total maximum daily load (TMDL) program and ensure that pollution control responsibilities are allocated to point and nonpoint sources in a fair and equitable manner. NACWA recommends that EPA reassess the watershed/TMDL rule to ensure that:

  • Designated uses of waterbodies and water quality criteria are reviewed as the first step in the TMDL process to ensure water quality objectives are appropriate and attainable.
  • Pollution contributions from unregulated nonpoint sources are addressed, and all sources of pollution bear their equitable share of the cost of meeting the nation’s water quality goals and objectives.
  • A broader range of nonpoint source control activities are covered under the definition of reasonable assurance, so that municipalities, which hold many of the nation’s existing discharge permits, are not forced to remove increasingly minimal amounts of pollutants at an overly burdensome cost.
  • EPA does not unduly restrict additional loadings from point sources during the time between “impaired waters listing and TMDL development”, recognizing that point sources may be minimal contributors to impairment and that suspected impairment may be the result of a concentration-based toxicity rather than total mass of pollutants discharged.
  • States are required to adopt a translator mechanism or methodology by which it will implement specific narrative standards prior to use of these standards for TMDL listing or development.
  • The recommendation of the National Research Council, including the use of adaptive TMDL implementation, are adequately addressed.

See NACWA’s Creating Successful Total Maximum Daily Loads for more information.