Making TMDLs Work for Your Watershed

If part or all of your local river or creek is impaired, take the initiative to find out what is being done on TMDLs in your area. Ask to review the data and information upon which
agency staff is basing its work on the TMDL. Ask to meet with agency
staff to review models and possible ways to reduce pollution. Spread the word about the restoration process in your community.

TMDLs seem technical -- and they can be. But even if you're not a technical expert, you can bring important information to the table that no one else may know. Local knowledge is usually key to a sucessful TMDL!

Here is a checklist of ideas to get you thinking about the ways you could be involved:

What's the problem?

Find out how the segments in your waterbody are defined by
the state.
Document the uses in each segment.
Ask if the segment size makes sense.
Find out what the state requires for gathering monitoring and
assessment data.
Ask whether one TMDL plan can address all of the problem pollutants a given segment.

What are the pollution sources and their cleanup responsibilities?

Examine the wasteload allocation to ensure that all necessary point
sources are included.
Examine the load allocation to ensure that all relevant nonpoint
sources are included.
Ask whether pollution trading will lead to unwanted consequences,
such as hot spots of poor water quality.
Look for the margin of safety. Is it explicitly described?
Examine whether the flow estimate used in the calculation of the
TMDL reflects all conditions, including the worst case condition.
Insist that the TMDL explicitly accounts for expected growth.

How much pollution can a waterbody handle?

Require a daily maximum in acceptable pollutant loadings.
Find the water quality criterion for the problem pollutant in your
state's water quality standards.
Request documentation for the agency's pollutant load allocation. Compare it to your knowledge of the pollutant sources.
Insist that the TMDL prohibit any load of persistent or
bioaccumulative pollutants.
Ask when the TMDL is designed to achieve water quality standards.

What changes will be required and when?

Require a TMDL implementation plan that includes a monitoring
plan, milestones for improvement, and a timeline for revisions.
Examine whether all point source permits are being adjusted
expeditiously according to the TMDL.
Demand "reasonable assurances" that reductions in nonpoint
contributions will occur.