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Friday May 16, 1997
AMSA Comments on EPA's TMDL Implementation Strategy
AMSA this week submitted its concerns and recommendations to the U.S. Environmental Protection Agency (EPA) on its draft Total Maximum Daily Load (TMDL) Implementation Strategy. The strategy explains EPA's vision and priorities, and sets forth steps it will take to help states meet TMDL program requirements. The strategy identifies issues for which EPA may develop guidance and/or make regulatory changes. The strategy also describes activities that are currently underway, have been recently initiated, or to which EPA will direct a greater portion of its available resources.
In its comments, AMSA notes that the draft TMDL Implementation Strategy generally addresses the major technical and public participation components necessary for successful implementation of the TMDL process, but expresses concerns about the lack of emphasis placed on nonpoint source regulation and funding issues. AMSA notes that the draft strategy associates implementation of nonpoint controls with available funding resources, reinforcing the inequity in EPA's authority-tight control on point sources, and marginal control authority on nonpoint sources. The Association recommends that "the implementation strategy should recognize the need for supplementary resources and funding from EPA at both the state and local level." It also advocates that minimum implementation standards for best management practices (BMPs) be established for nonpoint sources within 303(d) watersheds, and that water quality compliance activities be based on implementation of these BMPs, similar to EPA's national approach for urban stormwater permitting.
Additional AMSA comments/recommendations include: (1) EPA establishment of a process where designated uses are routinely reviewed for appropriateness, (2) support for a phased approach to TMDL development that would not inappropriately base significant decisions on inadequate data, and hamper efforts to refine loading allocations when more data become available, (3) support for modification of the current listing cycle from two to five years, (4) EPA focus on monitoring and assessment assistance on providing resources to support additional ambient monitoring efforts, and (5) EPA consideration of potential adverse impacts of a water pollution control program on a community when developing or implementing TMDLs.
EPA plans to issue an interim TMDL Strategy following comment review and has already begun implementing some of the Strategy's components. EPA will also consider recommendations from its TMDL Federal Advisory Committee (FACA) as they are developed and will periodically revise the strategy to reflect the committee's recommendations, other stakeholder feedback, and scientific developments. The next TMDL FACA meeting is scheduled for June 11-13, 1997 in Milwaukee, Wisc. Issues to be discussed include criteria for TMDL approval, and EPA management and oversight.
Plans for AMSA's 1997 Summer Conference -- Point & Nonpoint Sources . . . Balancing Responsibility for Pollution Prevention -- are well underway. An AMSA flyer that provides the conference agenda and registration materials will be forwarded to the membership and friends of the Association next week. Members planning to attend are encouraged to register for the conference and make their hotel reservations without delay. AMSA anticipates considerable interest in the conference topic and location.