Publication Summary

Ecology decided to re-examine the Total Maximum Daily Load (TMDL) program, seeking improvements in operations and refining workload estimates. This report presents a new workload model based on improvements to the existing program and the addition of new TMDL staff. With this model Ecology assessed the State′s ability to comply with the 15-year schedule of the memorandum of agreement with EPA, and examined Ecology′s ability to meet federal requirements associated with the 1998 Section 303(d) list.

Section 303(d) of the federal Clean Water Act requires states to develop a list of polluted waterbodies every two years. For each of those waterbodies, the law requires states to develop Total Maximum Daily Loads (TMDLs). A TMDL is the amount of pollutant loading that can occur in a given waterbody (river, marine water, wetland, stream, or lake) without becoming polluted. TMDLs are implemented through permits to point source dischargers and through non-regulatory programs for nonpoint sources.

The Washington State Department of Ecology is currently working under a memorandum of agreement (MOA) with the U.S. Environmental Protection Agency to address all polluted waterbodies on the 1996 303(d) list over a 15-year period. The MOA was developed in conjunction with a settlement between EPA and environmental interest groups who sued EPA over delays in completing TMDLs. The Ecology/EPA MOA was signed in October 1997.

In 1998, Ecology estimated the total TMDL program cost (to comply with the MOA) by developing a TMDL workload model (Wrye, 1998). This model served as the basis for redirecting existing staff and requesting additional resources from the State Legislature and EPA.

Two and one-half years after this initial workload model was developed, Ecology decided to re-examine the TMDL program, seeking improvements in operations and refining workload estimates. This report presents a new workload model based on improvements to the existing program and the addition of new TMDL staff. With this model Ecology assessed the State′s ability to comply with the 15-year schedule of the MOA and examined Ecology′s ability to meet federal requirements associated with the 1998 303(d) list.