Who Puts the DL in TMDL?

By. Neil Williamson, President

albemarle stream credit c-vileAs Albemarle County considers the funding source for state mandated Total Maximum Daily Load (TMDL) reductions in storm water,  The Free Enterprise Forum was curious who (and what) was responsible for these nefarious contributions to our waters.

Absent any locality specific data, we examined the TMDL existing conditions for the state of Virginia based on ChesapeakeStat [for the purposes of this examination we ignored wastewater (as it is mitigated under separate authority) and atmospheric contributions].

In each of the three pollutant measurements (Nitrogen, imagePhosphorous, Total Suspended Solids), Agriculture and Forestry are the largest contributors to the TMDL.  It could be generalized that Development contributes 15% of the storm water problem and rural areas (including agriculture) contribute 60% of the total problem.  Rural areas therefore contribute about 4 times more storm water pollution than developed areas.

While the significant rural area contribution may seem counter intuitive, there is good news.  Mitigating storm water contributions in the rural areas tend to be less expensive than retrofitting existing land uses in the development areas. 

One must consider not only the baseline but what the mandated 2025 TMDL goals strive to achieve.  Under the so called “TMDL diet” Agriculture is targeted to reduce its contribution of Phosphorous and Nitrogen by over 65% while Urban Areas are looking to cut their relative contributions to each by 25%.  The reality is that the cost for achieving a 25% reduction in the Urban Areas may prove to be greater than the cost of attaining the larger percentage rural area goals.

One could argue that the urban areas are only contributing to 15% of the problem and thus should only pay for 15% of the fix.  That is a fatally myopic view.  This is a community issue the entire community should come together to find cost efficient and effective solutions.

To date, Albemarle County has not developed a specific five year plan to meet the TMDL goals.  The estimated costs are instead based on the average cost to meet the TMDL targets.  If the goals can be most cost effectively met in the rural areas clearly that is where the programs should be instituted.

What types of projects might be funded?  The Chesapeake Bay Foundation has highlighted a number of  potential storm water funded projects that have community benefit beyond just improved water quality:

Photo: So just where exactly do stormwater fees go you ask? Try rain gardens, streambeds, ponds, and other job-creating projects that not only improve our water quality, but beautify our communities, too! Learn more in the Chesapeake Bay Foundation’s special investigative report on polluted runoff: www.cbf.org/PollutedRunoffReport

Based on all of the above, and our belief that storm water mitigation has a community wide benefit beyond just TMDL reduction.  We continue to support the concept of funding this program through the General Fund.  If there is a desire to create incentives for storm water mitigation, a separate grant program could be developed that would more efficiently deliver real value than small credits on a monthly utility fee.

Respectfully Submitted,

Neil Williamson, President

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20070731williamson Neil Williamson is the President of The Free Enterprise Forum, a privately funded non partisan public policy organization covering the City of Charlottesville as well as Albemarle, Greene, Fluvanna, Louisa and  Nelson County.  For more information visit the website www.freeenterpriseforum.org

Photo Credits: C-ville, Free Enterprise Forum, Chesapeake Bay Foundation

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