ADAPTIVE IMPLEMENTATION FOR SEDIMENTBASED TMDLS BACWAS COMMENTS

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ADAPTIVE IMPLEMENTATIONFOR SEDIMENT-BASED TMDLS
BACWAS COMMENTS

• James M. Kelly
• Chair, Bay Area Clean Water Agencies
• Director of Operations
• Central Contra Costa Sanitary District
• May 4, 2004

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Assessing the TMDL Approach to Water Quality
Management

• 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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Assessing the TMDL Approach to Water Quality
Management(continued)
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.
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CENTRAL CONTRA COSTA SANITARY DISTRICT NPDES
PERMIT

• REGIONAL MONITORING PROGRAM
• The Discharger shall continue to
• participate in the Regional Monitoring
• Program (RMP) to characterize the
• ambient background water quality of
• trace substances in San Francisco Bay,
• and to assist the Regional Board in TMDL
• development.

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CENTRAL CONTRA COSTA SANITARY DISTRICT NPDES
PERMIT (continued)

• The Dischargers continued
• Participation in the RMP will offset
• some of the more extensive effluent
• and receiving water self-monitoring
• requirements that may otherwise
• be imposed.

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BACWA BAY AREA CLEAN WATER AGENCIES

• Collect and treat wastewater from over 5,000,000
  in San Francisco Bay area
• Invested billions of dollars in treatment
  facilities
• Spend 500 million per year to treat
• Invest millions of dollars per year in pollution
  prevention

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BACWA BAY AREA CLEAN WATER AGENCIES

• Members in Regional Monitoring Program
• Nominally 1 percent of source of listed
  pollutants
• Co-founder of Clean Estuary Partnership (CEP)
• Permit compliance is a core value for BACWA
  agencies

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CLEAN ESTUARY PARTNERSHIP(CEP)

• Formed to set TMDLs done
• Focus evolved to include water quality
  attainment strategies
• Effort now includes conceptual model / impairment
  assessment for listed pollutants

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WHAT ARE VIABLE POSSIBLE / VIABLE IMMEDIATE
ACTIVITIES

• CEP and its studies
• Pollution Prevention / Dental Program
• Support studies to further define needed action

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ARE YOU WILLING TO ACCEPT RESPONSIBILITY FOR
IMMEDIATE ACTIONS?

• BACWA is taking action
• BACWA doesnt want our good deeds to be
  punished
• BACWA supports defining problem and needed
  actions

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WHAT DOES BACWA NEED TO KNOW

• That BACWAs money and commitments will result
  in environmental improvements
• Will there be a workable pollutant trading
  policy
• BACWAs actions relate to BACWAs
  responsibilities

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WHAT ARE THE BARRIERS / WHAT DATA IS NEEDED

• Vested interests
• Permit action that puts BACWA member agencies
  non-compliance with no measurable environmental
  benefit
• CEP to continue to evolve
• Partners
• Actions

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ARE YOU WILLING TO PAY MORE FOR STUDIES?

• We are now!
• CEP / RWQCB have made notable progress
• CEP has created forum for input from all
  interested parties
• Role of the RMP?