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PROVIDING FISCAL RESPONSIBILITY IN THE TMDL PROCESS: A WWTP STAKEHOLDER GROUP'S PERSPECTIVE

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In the fall of 2003, the State of Illinois Environmental Protection Agency (Agency) released three draft total maximum daily loads (TMDLs) that were the first to significantly impact point source dischargers in Illinois. Two of these draft TMDLs, for the East Branch of the DuPage River (EBDR) and Salt Creek (SC), addressed chloride/total dissolved solids (TDS)/salinity and dissolved oxygen (DO). The third, for the West Branch DuPage River (WBDR), addressed chloride/TDS/salinity only. All three of the TMDLs were for streams in urban watersheds which are point-source dominated during low flow months. Several publicly-owned and industrial wastewater treatment plants (WWTPs) discharge to these streams. All three of the draft TMDLs included provisions for reducing road salt runoff to address the chloride/TDS/salinity issues. The EBDR and SC draft TMDLs also included proposed reductions in summer WWTP effluent limits to 5 mg/L carbonaceous biochemical oxygen demand (CBOD) and 1 mg/L ammonianitrogen.

Several of the affected communities recognized the potentially high cost of TMDL implementation as drafted, particularly for the WWTPs in the EBDR and SC watersheds. The SC draft TMDLs estimated the cost of compliance at the WWTPs in that watershed at 18 million, a figure that appeared significantly low based on independent reviews. The WWTP stakeholders were particularly concerned that the draft DO TMDLs did not address nutrients, and yet they recognized that nutrients affect DO and they will need to spend additional millions of dollars complying with upcoming nutrient water quality standards in the next five to ten years. The WWTP stakeholders, therefore, put forth a concerted effort to review and comment on the draft TMDLs. A well-respected organization, the Illinois Association of Wastewater Agencies (IAWA), hired a consultant to review the Agency's process for developing draft TMDLs, solicit comments from other IAWA members, and compile the consultant's and members' comments for submission to the Agency. Many individual communities in the watersheds also reviewed and commented on the documents, as did interested environmental groups.

The IAWA and some of the individual commenters concluded there were numerous shortcomings in the process used to develop the TMDLs and in the DO modeling and allocation development. They recommended the Agency focus on additional monitoring, reassessment of water quality standards, and potential revisions to waterbody use designations prior to finalizing the draft TMDLs or developing additional TMDLs in Illinois. Recommendations included a phased TMDL and development of new scenarios that would result in a higher benefit for the cost, including nonpoint source controls and possible dam removal. The comments were wellreceived by the Agency. The Agency had already made changes to their TMDL development process and has recently proposed changes to the first EBDR and SC TMDLs to allow a more phased, adaptive approach to implementation. The Agency proposed the formation of a local watershed committee to help formulate, revise, and implement the plan. It appears the revised TMDLs will result in a more scientific and reasonable approach, with more responsible spending of rate payer's dollars. The Agency is also considering changes to water quality standards (WQS) including the state's designated use classification system. This experience highlights the value of true stakeholder participation in the TMDL process. The information presented will benefit owners of WWTPs and other stakeholders discharging to urban impaired waters for which TMDLs are being developed.
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Document Type: Research Article

Publication date: 2004-01-01

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