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TMDL History

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CREST
Cleaner Rivers through Effective Stakeholder-led TMDLs
crestmdl.org

Regulatory Background of Total Maximum Daily Loads (TMDLs)

This summary provides a brief overview of the regulation requirements related to the more than 60 Total Maximum Daily Loads (TMDLs) anticipated to govern the discharge of wastewater, urban runoff and stormwater in the Los Angeles River, Ballona Creek, Dominguez Channel, and Santa Monica Bay watersheds within the City of Los Angeles.

A Total Maximum Daily Load establishes a maximum limit for a specific pollutant that can be discharged into a water body without causing it to become impaired.

In 1998, the National Resources Defense Council (NRDC), along with other environmental groups, sued the EPA for failure to move forward in a timely manner with this program. This action resulted in a consent decree and a 13-year schedule to complete over 90 TMDLs, more than 60 affecting the City of Los Angeles. With such an aggressive schedule, the TMDL Program has become a top priority for both the State and Regional Board, as well as for the City of Los Angeles.

Thus far, thirteen TMDLs having an impact on the City have been adopted. The adoption process can be lengthy and involves the approval of the following entities: Los Angeles Regional Water Quality Board (LARWQCB), State Water Resources Control Board (SWRCB), Office of Administrative Law, and the United Sates Environmental Protection Agency (USEPA).

The following list identifies adopted TMDLs with their effective dates:

• Los Angeles River Trash TMDL (Sept 19, 2001)
Ballona Creek and Estuary Trash TMDL (Sept 19, 2001)
• Santa Monica Bay Beaches Bacteria TMDL – Dry Weather (July 15, 2003)
• Santa Monica Bay Beaches Bacteria TMDL – Wet Weather (July 15, 2003)
• Marina Del Rey Back Basin & Mother’s Beach Bacteria TMDL (March 18, 2004)
• Los Angeles River Nitrogen TMDL (March 23, 2004)
• Los Angeles Harbor (Inner Cabrillo Beach / Main Ship Channel) Bacteria TMDL (March 10, 2005)
• Ballona Creek Metals TMDL (January 11, 2006)
• Ballona Creek Estuary Toxic Pollutants TMDL (January 11, 2006)
• Los Angeles River and Tributaries Metals TMDL (January 11, 2006)
• Marina del Rey Back Basins & Mothers Beach Toxic Pollutants TMDL (March 22, 2006)
• Ballona Creek, Ballona Estuary, & Sepulveda Channel Bacteria TMDL (April 27, 2007)
• Machado Lake Trash TMDL (March 6, 2008)

TMDLs in Development

• Machado Lake Nutrients TMDL
• Los Angeles River Bacteria TMDL
• Dominguez Channel Bacteria TMDL
• Dominguez Channel Toxic Pollutants TMDL

TMDLs will be enforced through State and Federal discharge permits issued to the City such as the Municipal Stormwater National Pollutant Discharge Elimination System (NPDES) permit and Publicly Owned Treatment Works (POTWs) permit. Violation of these permits can result in exposing the City to both civil and criminal liabilities.

As part of this effort, the City of Los Angeles, Department of Public Works, Bureau of Sanitation is responsible for responding, with Los Angeles City Council concurrence, to draft TMDLs proposed by the Regional Board.

Once the TMDLs become effective, the Bureau of Sanitation is responsible for complying with the requirements of the TMDL. For each TMDL adopted the following requirements usually include, but are not limited to the following activities.

• Prepare & Implement a Monitoring Plan
• Prepare & Implement a Implementation Plan
• Conduct special studies (if necessary)
• Achieve compliance with the water quality standards

The passage of Proposition O in the Fall of 2004 has provided much needed funding to push forward the City’s aggressive implementation program to ensure compliance with the early phases of TMDL Implementation.

EPA/Regional Board Draft TMDL Strategy Document
In December 2001, the EPA and Regional Board released a preliminary draft of their new TMDL strategy. This document responds to many comments made by the regulated community that the consent decree approach of developing TMDLs on a singular one-by-one approach has been ineffective and has made planning for implementation a near impossible task.

This new plan proposes to work within the consent decree’s 13-year deadline but now bundles the TMDLs by watershed so that a more holistic approach will be provided and plans can be made for treatment or other implementation options that will address multiple pollutant concerns. Guidance for stakeholder-led TMDL development is also included. The City embraced this concept and through the efforts of the City lead working group, Clean Rivers through Effective Stakeholder TMDLs (CREST), the City is working towards ensuring TMDLs are scientifically-based and negotiating with the regulatory agencies regarding the final TMDL language.

Long Range Planning – Water Quality Master Plan
The Los Angeles City Council passed a motion on March 2, 2007, to prepare a master plan for improving water quality in the ocean, rivers, lakes, and streams. To guide this extraordinary effort, the Watershed Protection Division of the City of Los Angeles, Department of Public Works, Bureau of Sanitation prepared two documents:

• The Water Quality Compliance Master Plan for Urban Runoff is a technical document that describes, in detail, the current status of the City’s waters, future plans for urban runoff management, cost estimates for funding, and proposed financing solutions.

• The Urban Runoff Plan is a document that summarizes the major elements of the Water Quality Compliance Master Plan for Urban Runoff.