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E-M:/ Total Maximum Daily Load in the NY Times -Reply

Enviro-Mich message from "Charles Cubbage" <CubbageC@state.mi.us>

Thanks for the item on Total Maximum Daily Load (TMDL).  As most of you may know, in simplified version, TMDLs are called for by the Clean Water Act that requires states to identify impaired waters and then set a total max daily load (TMDL - for each pollutant), based essentially on the watershed's carrying capacity - that level which is supposed to keep the water fishable and swimable.  

Michigan agencies and interested groups including env and citizen reps are involved in watershed management and water resource protection very heavily now on a number of fronts.  MDEQ is revising its list of impaired waters from 34 to what will likely be 300+ (for the TMDL program).  

Also, a state-wide non-point source relative risk work group is meeting, as is a state-wide water quality trading work group.  For the un-initiated, non-point source (NPS) includes items such as ag, development, urban and other storm water run off, golf courses, road maintenance & development.  In any given watershed, the mix of who is doing what to whom is variable.  

I hope that as the opportunity to be involved arises, you do so.  For many people this electronic bulletin board is a good way to ask questions and at the least to keep informed.  I hope those of us who are already involved can keep info flowing.  I will try to do so as best I can, but like most of you, I retrieve somewhere around 100 messages per day.  

As many of you know, I belong to East Mich Env Action Council but also wear an MDA hat as Science Advisor.  Regardless of the hats we wear, protecting our water resources for ourselves, our children, and for the sake of the ecosystems that cannot speak for themselves, needs to be our collective focus.  The TMDL, water qual trading, and NPS recommendations will be important.  I strongly believe that ag activities need not conflict with env resources.  Sustainable human activities, whether ag related or urban can be designed to be environmentally friendly and economically feasible if we seek out the options.  But we need to all sit at the table in order to fit it together.  

With that in mind, I am heavily involved in the Kalamazoo Water Quality Demonstration Project.  It deals with point-non-point phosphorus water qual trading credits.  The Kazoo Foundation has received significant grants and private industry  funding to implement trading credits.  A diverse stake-holder group has formed a steering committee and numerous subcommittees to oversee and implement the project.  This includes the Kazoo Env Council, MDA, Mich Farm Bureau, Mich Ag Stewardship Assoc,  Natural Resource Conservation Service (NRCS), MDEQ, farmers, etc.  Anyone interested in learning more about the project, or with input & inquiries, feel free to respond back to me.  A good chunk of the funding will be used to monitor NPS improvements and asses the effectiveness of the program with about $100,000 going toward NPS controls.   The basic idea is to develop a model system where the private sector pays NPS  to reduce stream phos loading so that increased production can occur at the point source (but with a reduced background loading because the NPS has already taken phos out).  

Before you faint ---- Key constraints are that 1) NO localized impairment will be allowed and 2) watershed loading (along the area of concern) must be reduced with each trade.  Each trade is on (at the very least) a 2 for 1 basis; i.e., for 2 pounds of phos removed by the NPS,  only 1 pound phos to be added by the point source - The result is a net reduction of phos loading in the river. 

We have had long and ardous discussions within the Kazoo group and continue to move ahead.  Monitoring is a big part of this effort because we do not want paper trades.  Assurances and accountability are part of the planned expenditures.  Like I said, feel free to give a holler my way and I or the Kazoo project will respond as best we can.  I think we have thought of most of the problems and some of the answers, but we need all the help we can get ( that's a collective "we" that includes us all!!!)


Chuck Cubbage 

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