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actions envisioned in the TMDL plan in place. Such actions could include limitations on point sources beyond technology-based effluent standards. Also, using best management practices for nonpoint sources, as well as addressing pollution problems, might be part of implementation, although these actions are not required by Section 303d. 1 The results of implementation actions need to be assessed before a waterbody can be removed from the list. Monitoring in this phase is necessary to measure the success (or failure) of the plan. Chapter 5 discusses postimplementation monitoring and a strategy for assuring that the best available science is used in the TMDL implementation phase. When the monitoring proves that the implementation is successful (i.e., the water quality standards are met), the waterbody can be delisted.


Brady, D. 2001 . Chief of the Watershed Branch in the Assessment and Watershed Protection Division in the EPA Office of Wetlands, Oceans and Watersheds. Presentation to the NRC Committee. January 25, 2001.

Environmental Protection Agency (EPA). 1991 . Guidance for Water Quality-based Decisions: The TMDL Process. Washington, DC : EPA Assessment and Watershed Protection Division .

General Accounting Office (GAO). 2000 . Water Quality - Key EPA and State Decisions Limited by Inconsistent and Incomplete Data. GAO/RCED00-54. Washington, DC : GAO .

Houck, O. A. 1999 . The Clean Water Act TMDL Program: Law, Policy, and Implementation. Washington, DC : Environmental Law Institute .

Rodgers, W. H., Jr. 1994 . Environmental Law, Second edition. St. Paul, MN : West Publishing Co.

1 Whether nonpoint source controls are required as part of the TMDL program is the source of much of the debate, especially with regard to the 2000 regulations that are now on hold. Under the current (1992) regulations, 303d is a planning exercise only. Implementation must be by some other provisions of the CWA or other programs. Also, states differ in their ability to enforce use of certain best management practices.

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