Should "daily" Mean "daily" in TMDL
In the thousands of pages of legislative history associated with the Clean Water Act and its various amendments, there are only a handful of references to "total maximum daily loads." Of those, none addressed what Congress intended by the phrase "daily load." For many years, EPA interpreted it loosely to allow for non-daily loads where appropriate to meet water quality objectives. Last year, a federal appellate court invalidated EPA's interpretation. This manuscript explores the tortured history of the daily load debate and EPA's options for meaningfully responding to the court's ruling.
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Document Type: Research Article
Publication date: 2007-10-01
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