How will the Bay TMDL be implemented? What is the relationship between the TMDL and the Watershed Implementation Plan (WIP)? The accountability framework includes Watershed Implementation Plans (WIPs) developed by the states, two-year milestones identified in the WIPs, EPA’s tracking and assessment of restoration progress and, as necessary, specific federal actions if jurisdictions do not meet their commitments. The Lower Susquehanna Riverkeeper is particularly interested in ensuring that TMDL timelines are met on the state level. It is vital that EPA demand accountability, transparency, and enforcement throughout the Bay TMDL implementation process.
What are the consequences if a segment or basin fails or exceeds an assigned loading level, or if two-year milestones are not met? If state actions fall short, EPA is prepared to impose consequences to assure progress. For example, EPA could expand stormwater permit coverage to currently unregulated sources, object to stormwater permits and increase program oversight, or require additional reductions of loadings from point sources. At this time (Spring 2012) none of these backstop measures have been implemented.
When does the TMDL anticipate the Bay will be restored? All pollution control measures will be in place by 2025. While it will take years after 2025 for the Bay to fully heal, EPA expects some areas of the Bay will recover before others and there will be gradual improvement in water quality as controls are put in place around the watershed. It is important to remember that as localities implement their individual programs reducing pollution loads we will first see local benefits via improvements to local waterways. In this way, cleaning up local streams and rivers gives direct benefits to local communities and economies and indirectly improves the Bay.
How will the TMDL implementation be funded? PA is hardpressed to find state, county and local finances necessary to fully implement TMDL requirements. Wastewater and stormwater system upgrades will be funded primarily by ratepayers. These rate hikes are because a good portion of these infrastructure systems have not been updated in a timely fashion previously, such that the full weight of these upgrades will be felt in the next 10+ years. In addition to technological upgrades designed to reduce pollution loads, PA anticipates an expanded nutrient trading program that in theory allows sectors to trade credits and reduce nutrient loads more cost effectively. We are closely watching PA’s implementation of this program to realistically assess the benefits – if any – of nutrient trading on the ground.