TMDLs:. The Regulatory Transmogrification of Nuisance. CWA “fishable-swimmable” goal.
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The Regulatory Transmogrification
TMDL = WLA + LA + MOS
Waste Load Alloca-tion
Load Alloca-tion (Nonpoint Sources)
Margin of Safety (fudge for future development,poor data)
(or, why you can’t get there from here, but perhaps still ought to try)
The logic of TMDLs is political rather than legal or economic.By starting from impacts in the stream, you can get political buy-in from interests that can’t be regulated directly.