CSPA joined a broad coalition of 40 environmental organizations urging the U.S. Environmental Protection Agency (EPA) to retain the Agency’s 2010 revisions to the 2002 memorandum regarding pollutant load allocations from point and nonpoint sources in Total Maximum Daily Load (TMDL) plans. EPA has been under heavy pressure to rescind the 2010 revisions that strengthened the TMDL requirements.
The 2010 revisions recommended that numeric effluent limits be included in storm water permits as well as guidance on improving storm water programs with: BMP performance monitoring where numeric effluent limits are infeasible; numeric targets for surrogates of pollutant parameters; and disaggregation of storm water sources in TMDLs. Coalition Letter to EPA