Navigating the TMDL Process
Paul L. Freedman
Narrative water quality criteria are an integral component of States water quality standards but they pose special problems when incorporated into the TMDL process. The TMDL process is typically a quantitative activity, defining numeric allowable loads necessary to meet a numeric water quality objective. Narrative criteria confound development of quantitative TMDLs, due to the absence of these numeric criteria. The objective of this research was to improve the methods for addressing narrative water quality criteria in the TMDL process. The problems associated with narrative criteria in the TMDL process are known in general terms but, prior to this research, there has not been a thorough review of the use of narrative criteria in TMDLs nor broad guidance on how to address narrative criteria in the TMDL process. The approach taken for this research was to define the range of problems associated with all types of narrative criteria by means of a comprehensive review of 120 narrative TMDLs, and provide guiding principles to help address these problems.