Improving the TMDL process using watershed risk assessment principles.

Ecological risk assessment (ERA) evaluates potential causal relationships between multiple sources and stressors and impacts on valued ecosystem components. ERAs applied at the watershed scale have many similarities to the place-based analyses that are undertaken to develop Total Maximum Daily Loads (TMDLs), in which linkages are established between stressors, sources, and water quality standards, including support of designated uses. TMDLs focus on achieving water quality standards associated with attainment of designated uses. In attempting to attain the water quality standard, many TMDLs focus on the stressor of concern rather than the ecological endpoint or indicators of the designated use that the standard is meant to protect. A watershed ecological risk assessment (WERA), at least in theory, examines effects of most likely stressors, as well as their probable sources in the watershed, to prioritize management options that will most likely result in meeting environmental goals or uses. Useful WERA principles that can be applied to TMDL development include: development and use of comprehensive conceptual models in the Problem Identification step of TMDLs; use of a transparent process for selecting Numeric Targets for TMDLs based on assessment endpoints derived from the management goal or designated use under consideration; analysis of co-occurring stressors likely to cause beneficial use impairment based on the conceptual model; use of explicit uncertainty analyses in the Linkage Analysis step of TMDL development; and frequent stakeholder interactions throughout the process. WERA principles are currently most applicable to those TMDLs in which there is no numeric standard and, therefore, indicators and targets need to be developed, such as many nutrient or sediment TMDLs. WERA methods can also be useful in determining TMDL targets in situations where simply targeting the water quality standard may re-attain the numeric criterion but not the broader designated use. Better incorporation of problem formulation principles from WERA into the TMDL development process would be helpful in improving the scientific rigor of TMDLs.