TMDLs and Impaired Water Bodies

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The following was adapted from information taken from the website of California's State Water Resources Control Board (SWRCB). Water quality control agencies in other states should have similar programs.

Section 303(d) of the federal Clean Water Act (CWA) requires States to identify waters that do not meet water quality standards (called "impaired water bodies") after applying effluent limits for point sources other than publicly-owned treatment works (POTWs) that are based on the best practicable control technology currently available and effluent limits for POTWs based on secondary treatment. States are then required to prioritize waters/watersheds for total maximum daily loads (TMDL) development (see below). States are to compile this information in a list and submit the list to USEPA for review and approval. This list is known as the 303(d) list of impaired waters (303(d) list).

The State Water Resources Control Board (SWRCB) and Regional Water Quality Control Boards (RWQCBs) have ongoing efforts to monitor and assess water quality, to prepare the Section 303(d) list, and to develop TMDLs. The Clean Water Act does not require the implementation of TMDLs, only the development of the document. A federal regulation established in August 2000 that became effective in October 2001 requires that implementation plans be developed along with the TMDLs.

Ambient Monitoring

The SWRCB has developed a new program to monitor the quality of the State's Waters. The Surface Water Ambient Monitoring Program (SWAMP) will assess impacts on beneficial uses, the locations of polluted sites, the areal extent of pollution, and trends in water quality.

Section 303(d) List

California's most recent 303(d) list, as contained in the state's Integrated Report, can be found here. The list is updated approximately every two years. Priorities (high, medium, low) are assigned to each pollutant causing impairment at each listed water body, and TMDLs are developed for each pollutant according to a schedule shown on the 303(d) list.

Total Maximum Daily Loads (TMDLs)

TMDLs are documents that describe a specific water quality attainment strategy for a water body and related impairment identified on the 303(d) list. TMDLs may include more than one water body and more than one pollutant. The TMDL defines specific measurable features that describe attainment of the relevant water quality standards. TMDLs include a description of the total allowable level of the pollutant(s) in question and allocation of allowable loads to individual sources or groups of sources of the pollutant(s) of concern.

Typical categories of pollutants include metals, pesticides, pathogens (bacteria and viruses or sometimes specified as "high coliform count"), nutrients, priority organics, sedimentation/siltation, salinity/TDS/chlorides, and trash.

Examples of TMDLs include the ones established by the San Diego Regional Water Quality Control Board (SDRWQCB) for inland and coastal waterways in San Diego County and Southern Orange County. The requirements for implementation of these TMDL programs are contained in Attachment E to the Regional Municipal Separate Storm Sewer System (MS4) permit issued by the SDRWQCB. The requirements for implementation of the indicator bacteria TMDLs have led to a project to determine whether and to what extent data supports amending the objectives, implementation provisions for applicable TMDLs, or the TMDLs themselves. In support of this objective, The SDRWQCB is performing a Cost-Benefit Analysis to "evaluate the costs and benefits of meeting numeric fecal indicator bacteria targets established by the 2010 Bacteria Total Maximum Daily Load for Beaches and Creeks in the San Diego Region (Bacteria TMDL). Programs and actions to achieve TMDL compliance are costly both in terms of financial costs of capital investment and maintenance as well as opportunity costs associated with other investments foregone, but also provide multiple benefits to the community. CBA results will be used by the Steering Committee members to inform policy decisions." More on this.

This article is part of a series on Clean Water which looks at various threats to the water quality of our oceans, and the negative impacts polluted waters can have on the environment and human health.

For information about laws, policies, programs and conditions impacting water quality in a specific state, please visit Surfrider's State of the Beach report to find the State Report for that state, and click on the "Water Quality" indicator link.