M2 PM Non-Point Source Pollution and TMDLs
Monday, 14 November 2005: 1:50 PM - 5:30 PM in Ballroom 2

(LEB-1117-832239) Paradigms lost: TMDLs and the failure of implementation plans.

Lebednik, P.¹, ¹ LFR Levine-Fricke, Emeryville, CA, USA

ABSTRACT- The advent of TMDL regulatory processes holds substantial promise for reducing impairment of water bodies, particularly those impairments associated with non-point sources, thereby leading to further rehabilitation of the nation's aquatic ecosystems. However, it has become apparent that the paradigm employed in developing technical guidance for performing TMDLs is inappropriate for contaminants with certain environmental characteristics. Use of the existing paradigm in such cases is unlikely to generate results that will accomplish reduction of water body impairments for these contaminants. This prospect is especially problematical because of the time and financial resources that may be expended on these TMDL evaluations and their resulting implementation plans. The purposes of this presentation are to identify those classes of contaminants for which the paradigm is inappropriate and to discuss an alternate TMDL approach for those contaminants that is more likely to provide the information that would be efficacious for reducing impairment. Key aspects of this presentation will be illustrated using information and evaluations associated with 303(d) list contaminants from the San Francisco Bay Estuary.

Key words: tmdl, contaminants, impairment