Square Peg in a Round Hole: Are Flow-Based TMDLs the Wrong Approach to Manage Stormwater Runoff?

摘要

The regulatory landscape for stormwater management is in the midst of significant changes. As regulations and our understanding of stormwater continue to evolve, the sector is faced with considerable opportunities and challenges associated with how best to address the water quality and quantity impacts from stormwater runoff in a technically sound and cost-effective manner. Attempting to fit this square- peg of water pollution into the round hole of existing regulatory programs was the issue raised in the recent Acco-tink Creek Total Maximum Daily Load (TMDL) case, which focused on the use of stormwater runoff as a surrogate for legally recognized pollutants.This case has spawned a wide range of opinions on the potential im-plications of the ruling, especially as it relates to the ability of EPA to regulate stormwater flow.