The Virginia TMDL implementation process is moving ahead. Planning District Commissions have forwarded requests to municipalities for data to be submitted by February, 2012, but state Colleges and Universities may not be fully included in this process. Often municipalities may submitt land cover data and BMP data on behalf of the institution without consultation or submit data without including the land area of these campuses. Either approach can leave the institution unrepresented in the process and may result in increased TMDL reduction allocations.
The following is a summary of recent conversation with DCR on this topic:
- If a College or University has an MS4 permit, the institution will report compliance with TMDL directly to DCR.
- DCR is committed in concept to TMDL reductions as outlined in the Phase 1 Watershed Implementation Plan ( WIP 1)
- DCR should have actual reduction targets by early 2012., but will be close to WIP 1 targets as follows:
- 9% reduction – nitrogen
- 16% reduction – phosphorous
- 20% reduction – sediment
- TMDL reductions will be accordance with the following schedule:
- 2013-18 5% of total required reduction
- 2018-23 further 35% reduction (40% cumulative of total required reduction)
- 2023-28 further 65% reduction (100% cumulative of total required reduction)
(Note: timing of implementation is inconsistent with the TMDL.)
- Existing BMPs constructed in 2006 or earlier do not count toward TMDL reduction credit as they have already been factored into the model.
- Colleges and Universities will also need to comply with local TMDLs due to impaired waters in addition to the statewide TMDLs.
While this is the latest information, this process is changing almost daily as DCR works with EPA and stakeholders. Stay connected to the Inlet.