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lection and tools of analysis) in order to minimize the likelihood of future errors.

Many debates in the TMDL community have centered on the use of “phased” and “iterative” TMDLs. Because these terms have particular meanings, this report uses a more general term—adaptive implementation. 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. Plans for future regulatory rules and public spending should be tentative commitments subject to revision as we learn how the system responds to actions taken early on.

Like other chapters, this chapter discusses a framework for water quality management (shown in Figure 5-1, which is the same as Figure 3-1). Before turning to adaptive implementation, it discusses an important prior step—review of water quality standards. Before a waterbody is placed on the action (303d) list, it is suggested that states conduct a review of the appropriateness of the water quality standard. The standards review may result in the water not being listed as impaired if the standard used for the assessment was found to be inappropriate. On the other hand, the same process may result in a “stricter” standard than was used in the assessment process, in which case the waterbody would have a TMDL plan developed to achieve that revised standard. A review of the water quality standard will assure that extensive planning and implementation actions are directed toward clearly conceived designated uses and associated criteria to measure use attainment.


Water quality standards are the benchmark for establishing whether a waterbody is impaired; if the standards are flawed (as many are), all subsequent steps in the TMDL process will be affected. Although there is a need to make designated use and criteria decisions on a waterbody and watershed-specific basis, most states have adopted highly general use designations commensurate with the federal statutory definitions. However, an appropriate water quality standard must be defined before a TMDL is developed. Within the framework of the Clean Water Act (CWA), there is an opportunity for such analysis, termed use attainability analysis (UAA).

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