ADAPTIVE IMPLEMENTATIONFOR SEDIMENT-BASED

TMDL’S BACWA’S COMMENTS

James M. KellyChair, Bay Area Clean Water Agencies

Director of OperationsCentral Contra Costa Sanitary District

May 4, 2004

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 oflimited scope commensurate with availabledata and information to continuously improveour understanding of a problem and its solutions, while at the same time making progress toward attaining a water qualitystandard.

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.

CENTRAL CONTRA COSTA SANITARY DISTRICT

NPDES PERMIT

REGIONAL MONITORING PROGRAMThe Discharger shall continue to participate in the Regional MonitoringProgram (RMP) to characterize theambient background water quality oftrace substances in San Francisco Bay,and to assist the Regional Board in

TMDLdevelopment.

CENTRAL CONTRA COSTA SANITARY DISTRICT

NPDES PERMIT (continued)

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

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

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

CLEAN ESTUARY PARTNERSHIP

(CEP)

Formed to set TMDL’s doneFocus evolved to include

water quality attainment strategies

Effort now includes conceptual model / impairment assessment for listed pollutants

WHAT ARE VIABLE POSSIBLE / VIABLE IMMEDIATE

ACTIVITIES

CEP and its studies

Pollution Prevention / Dental Program

Support studies to further define needed action

ARE YOU WILLING TO ACCEPT RESPONSIBILITY FOR IMMEDIATE ACTIONS?

BACWA is taking action BACWA doesn’t want our

good deeds to be punished BACWA supports defining

problem and needed actions

WHAT DOES BACWA NEED TO KNOW

That BACWA’s money and commitments will result in environmental

improvements Will there be a workable

pollutant trading policy BACWA’s actions relate to

BACWA’s responsibilities

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

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?