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<br />002969 <br /> <br />Western Governors' Association <br />Recommendations to the Environmental Protection Agency <br />and <br />Federal Advisory Committee on Total Maximum Daily Loads <br />February 1998 <br /> <br />1. FUNDING - States have committed significant resources to develop and manage the <br />point source programs called for in the Act, A major shift is now occurring that will <br />move program direction from a past focus on regulating point sources, to a watershed <br />approach that seeks to integrate non-point and point sources. We support this shift in <br />overall program vision, Western states are very concerned about both state capacity and <br />the federal regulatory or policy framework needed to implement the new approach. <br />Sufficient funding to address this new watershed focus is not presently available. As the <br />WGA stated in a recent letter to OMB Director Raines (attachment 2), increased TMDL <br />funding for states is critical if the goals of the Act are to be achieved in a timely manner. <br /> <br />EPA should provide funding to support the states' priorities and remove the caps <br />presently limiting certain program funds, In addition to funding state programs, EPA <br />should increase technical assistance to states, including assignment of federal employees <br />to work directly with the states in priority programs and projects. <br /> <br />We recognize that some of the funding issues may be beyond the scope of the <br />committee's charge. but we believe it is important to note the intenelationship of properly <br />funded programs with the success of those programs. Limits in available funds will <br />require that states have flexibility to ensure that individual state priorities are addressed. <br />The Federal Advisory Committee should note this issue and its relationship to future EP A <br />guidance. <br /> <br />2. FLEXIBILITY - Experience has demonstrated that as states implement TMDL <br />programs, flexibility and adaptability are key elements to successful state programs. The <br />unique climate conditions, habitat alterations, hydro modifications, streamflow <br />alterations, water temperature problems. etc., in the West require that states use, and in <br />some cases create, a wide variety of tools to develop and implement a comprehensive <br />TMDL program. Program guidance from the EP A should recognize regional and site- <br />specific considerations and should avoid an approach with specific prescriptions for states <br />to follow. <br /> <br />3. ADAPTIVE MANAGEMENT AND VOLUNTARY MEASURES - In the West, <br />many of the TMDLs that are developed will address non-point sources. The Clean Water <br />Act should be interpreted to allow for an adaptive interactive approach for state <br />implementation of non-point sources and the attendant TMDLs. In many cases it will not <br />be possible to be certain in advance that initial measures implemented for non-point <br />sources will achieve water quality standards. TMDLs should be approved if they contain <br />measures and commitments designed to achieve water quality standards over time, with a <br />commitment to monitor and measure effectiveness and revise or replace measures which <br />are insufficient, <br />