Assessing the TMDL Approach to Water Quality Management (2001) / Chapter Skim
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5 Adaptive Implementation for Impaired waters
5 Adaptive Implementation for Impaired waters
Pages 89-102
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From page 89... ...
Adaptive implementation simultaneously makes progress toward achieving water quality standards while relying on monitoring and experimentation to reduce uncertainty. SCIENCE AND THE TMDL PROCESS The planning sequence of moving from data to analysis to information and knowledge is supposed to provide confidence that the sometimes costly actions to address a water quality problem are justified.
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From page 90... ...
Adaptive implementation is, in fact, the application of the scientific method to decision-making. It is a process of taking actions of limited scope commensurate with available data and information to continuously improve our understanding of a problem and its solutions, while at the same time making progress toward attaining a water quality standard.
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From page 91... ...
All I >I Waters Determine Des~na~d Use/ Standard ~ Screening < ~ Assessment r +1 I < ( I__< ) '< "Preliminary" List _ ~ I Full Assessment ~ion" List (SO3d)
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From page 92... ...
For example, TMDEs conducted in Louisiana resulted in the conclusion that even implementing zero discharge of a pollutant would not bring attainment of water quality standards (Houck, 1999~. A properly conducted UAA would have revealed the true problem naturally low dissolved oxygen concentrations before the time and money were spent to develop the TMDL.
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From page 93... ...
This is significant because EPA retains the authority to approve state water quality standards. These uncertainties discourage state use of UAA because there is no assurance that EPA will accept the result of the UAA effort as an alternative to a TMDE, especially if the EPA expectation for a UAA will result in significant analytical costs.
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From page 94... ...
The UAA will assure that before extensive planning and implementation actions are taken, there is clarity about the uses to be secured and the associated criteria to measure use attainment. UAA is especially warranted if the water quality standards used for the assessment were not well stratified.
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From page 95... ...
The commitment in the plan is to further evaluate such actions based on the collection of additional data, data analysis, and modeling. An adaptive implementation plan would specify analyses of specific long-term alter
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From page 96... ...
where they will be monitored as a part of the rotating basin process. A primary purpose of success monitoring is to establish compliance with water quality standards and ultimately make the delisting decision.
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From page 97... ...
can be expected to undergo more revisions before water quality standards (including designated uses) are met than will TMDL plans developed for simple systems.
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From page 98... ...
To achieve equivalency, these Toad reductions must have the same effect on meeting the water quality standard, which would normally be determined using a modeling approach as described in Chapter 4. It is quite possible that the nitrogen load reductions at the sources (the agricultural BMP and the wastewater treatment plant)
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From page 99... ...
Progressing Toward Adaptive Implementation The TMDL program is limited by an incomplete conceptual understanding of waterbodies and watersheds, by models that are necessarily abstractions from the reality of natural systems, and by limited data for testing hypotheses and/or simulating systems. As a result, it is possible for a waterbody to be identified as impaired when it is not; in such cases, the costs to plan and implement control actions are wasted.
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From page 100... ...
Given the often weak water quality standards that underlie a listing, the Tong lag times between actions taken and measured responses, and the uncertainty in our ability to predict what actions will secure a designated use, it is unrealistic to expect that there will be no changes in economic activity and in land uses in a watershed until the designated use has been achieved. A basis for accommodating growth and change in watersheds needs to be established as adaptive implementation proceeds.
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From page 101... ...
The adaptive implementation approach may require increased state assumption of responsibility for individual TMDEs, with EPA oversight focused at the program level instead of on each individual water segment. Conclusions and Recommendations The call for adaptive implementation may not satisfy those who seek more definitive direction from the scientific community.
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From page 102... ...
to incorporate the elements of adaptive implementation into TMDL guidelines and regulations. To increase the scientific foundation of the TMDL program, the scientific method, which is embodied by the adaptive implementation approach, must be applied to water quality planning.
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