Analysis of TMDL Implementation Rates in 

EPA Region 5 

FINAL REPORT 

December 1, 2009 

Watershed Branch (4503T) 

Office of Wetlands, Oceans, and Watersheds 

U.S. Environmental Protection Agency 

1200 Pennsylvania Ave. NW 

Washington, D.C. 20460 

 

Document # EPA841-R-09-005 
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Notices and Acknowledgements 

As a product of the TMDL Program Results Analysis Project, the EPA Office of Water funded the 

development of this document in part through contract # EP-C-08-004 with Tetra Tech, Inc., whose 

Cleveland, Ohio office gathered the project data and compiled this report. The collaboration of TMDL 

program leaders and staff within the six EPA Region 5 states -- Illinois, Indiana, Michigan, Minnesota, 

Ohio, and Wisconsin -- was essential to the success of this project. Publication does not signify that the 

contents necessarily reflect the views and policies of the Environmental Protection Agency or of any 

other organization represented in this document. Mention of trade names or commercial products does 

not constitute endorsement or recommendation for use. 

This document should be cited as: 

USEPA. 2009. Analysis of TMDL Implementation Rates in EPA Region 5: Final Report. Document 

#EPA841-R-005. Office of Water, US Environmental Protection Agency, Washington DC. 44 pp. 

This document and related resources can be found online at: 

http://www.epa.gov/owow/tmdl/results/
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Executive Summary 

The U.S. Environmental Protection Agency (EPA) Total Maximum Daily Load (TMDL) program has 

accounted for the listing of over 44,000 impaired waters nationwide and the development of over 

40,000 TMDLs since the program’s creation. Case-specific accounts of implementation are 

widespread, but the actual rate of implementing TMDLs nationally or regionally has remained virtually 

unknown because full census and tracking of every implemented practice would be an overwhelming if 

not impossible task. To gain insights on implementation, EPA’s TMDL Program Results Analysis 

Project conducted a sample-based analysis of TMDL implementation rates and characteristics in the six 

EPA Region 5 states (IL, IN, MI, MN, OH and WI). 

A probabilistic sample was drawn from all TMDLs established through FY2007. Sampled TMDLs 

were allocated proportionally to states based on each state’s total TMDL production. Regional but not 

specific state-level statistics were the goal of the study. Subpopulations of interest contrasted older 

(through FY2003) versus newer (FY2004 – FY2007) TMDLs, and nonpoint-source (NPS)-only 

TMDLs versus point source (PS)-only and mixed (PS/NPS) TMDLs. The project team extracted 

information on each of the 138 sample TMDLs and their proposed NPS and PS controls from EPA data 

systems in advance of working with each state to verify implementation rates and patterns across the 

Region. 

This assessment demonstrated that, within a +/- 10% margin of error at 90% C.I., an estimated 80.3% of 

Region 5 TMDLs were at least partially implemented. Full implementation was uncommon. No 

implementation was observed in approximately 20% of the sample, but the diffuse nature of control 

practices typical of many TMDLs made complete verification of every practice difficult. Among 

subpopulations, implementation rates did not differ significantly between older or newer TMDLs, but 

the mixed TMDLs implementation rate exceeded the NPS-only rate by 16.1%. Implementation plans 

existed for 79.6% of TMDLs, and NPS-only TMDLs showed more plans than the mixed TMDL 

subpopulation. TMDLs generated as part of large watershed, multi-TMDL efforts comprised 13.2% 

more of the newer TMDLs subpopulation than the older TMDLs subpopulation. 

Post-analysis steps included exploring GIS data on the watershed traits of each sampled TMDL for 

other possible associations with patterns of implementation, and evaluation of possible 

subcategorization of the ‘partially implemented’ samples to provide more detailed information. 

Analysis of predominant land cover in the samples’ watersheds did not reveal significant differences 

among implementation rates associated with urbanized, heavily agricultural, lightly agricultural, and 

rural non-agricultural watersheds. Efforts to further subcategorize samples that were initially classified 

as partially implemented were partially successful but substantially limited data and by the difficulty of 

consistently comparing widely variable TMDLs. 
TMDL Implementation Rates in EPA Region 5 Project Report 

Table of Contents 

Notices and Acknowledgements ..........................................................................................................ii

Executive Summary ............................................................................................................................iii

Table of Contents ................................................................................................................................ iv

List of Tables........................................................................................................................................ v

List of Figures ...................................................................................................................................... v

1 Introduction........................................................................................................................................... 1

2 Technical Approach .............................................................................................................................. 2

2.1 Subtask A: Project work plan and establishment of data collection protocols ............................. 2

2.1.1 Approved Sources of Information......................................................................................... 4

2.1.2 Data Recording ..................................................................................................................... 4

2.1.3 Description of Source Interactions........................................................................................ 5

2.1.4 Quality Assurance Procedures.............................................................................................. 7

2.2 Subtask B: Collect and Compile Field Data ................................................................................. 7

2.3 Subtask C: Organize findings and develop report......................................................................... 8

3 State Summaries.................................................................................................................................... 9

3.1 Illinois TMDL Summary .............................................................................................................. 9

3.1.1 Point Source Implementation................................................................................................ 9

3.1.2 Nonpoint Source Implementation ....................................................................................... 10

3.1.3 Information Sources............................................................................................................ 10

3.2 Indiana TMDL Summary............................................................................................................ 11

3.2.1 Point Source Implementation.............................................................................................. 12

3.2.2 Nonpoint Source Implementation ....................................................................................... 13

3.2.3 Information Sources............................................................................................................ 13

3.3 Michigan TMDL Summary ........................................................................................................ 14

3.3.1 Point Source Implementation.............................................................................................. 14

3.3.2 Nonpoint Source Implementation ....................................................................................... 15

3.3.3 Information Sources............................................................................................................ 16

3.4 Minnesota TMDL Summary....................................................................................................... 16

3.4.2 Point Source Implementation.............................................................................................. 19

3.4.2 Nonpoint Source Implementation ....................................................................................... 19

3.4.3 Information Sources............................................................................................................ 19

3.5 Ohio TMDL Summary................................................................................................................ 20

3.5.1 Point Source Implementation.............................................................................................. 20

3.5.2 Nonpoint Source Implementation ....................................................................................... 22

3.5.3 Information Sources............................................................................................................ 23

3.6 Wisconsin TMDL Summary....................................................................................................... 24

3.6.1 Point Source Implementation.............................................................................................. 25

3.6.2 Nonpoint Source Implementation ....................................................................................... 25

3.6.3 Sources of Implementation Information ............................................................................. 26

4 Results and Observations.................................................................................................................... 27

4.1 Data Updates............................................................................................................................... 27

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TMDL Implementation Rates in EPA Region 5 Project Report 

4.2 Project Results Summary ............................................................................................................ 27

4.3 Observations ............................................................................................................................... 32

4.3.1 Study Results ...................................................................................................................... 32

4.3.2 Study Design....................................................................................................................... 33

4.3.3 Gaps in Appropriate Information........................................................................................ 34

 4.4 Additional Analysis of Partially Implemented TMDLs.............................................................. 34 

Appendix 1: Definitions of Key Terms ...................................................................................................... 37

Appendix 2: Additional Analysis of Partially Implemented TMDLs......................................................... 39

Tables 

Table 2-1. Data elements included in each TMDL analysis form ................................................................3

Table 3-1. Summary of Illinois TMDLs. ......................................................................................................9

Table 3-2. Summary of online sources of implementation data. ................................................................11

Table 3-3. List of state and local contacts...................................................................................................11

Table 3-4. Summary of Indiana TMDLs. ...................................................................................................12

Table 3-5. Summary of online sources of implementation data. ................................................................13

Table 3-6. List of state and local contacts...................................................................................................14

Table 3-7. Summary of Michigan TMDLs. ................................................................................................14

Table 3-8. Summary of online sources of implementation data. ................................................................16

Table 3-9. List of state and local contacts...................................................................................................16

Table 3-10. Summary of Minnesota TMDLs..............................................................................................18

Table 3-11. Summary of online sources of implementation data. ..............................................................20

Table 3-12. List of state and local contacts.................................................................................................20

Table 3-13. Summary of Ohio TMDLs. .....................................................................................................21

Table 3-14. Summary of online sources of implementation data. ..............................................................23

Table 3-15. List of state and local contacts.................................................................................................24

Table 3-16. Summary of Wisconsin TMDLs..............................................................................................25

Table 3-17. Summary of online sources of implementation data. ..............................................................26

Figures 

Figure 3-1. Structural relationship of the database for analyzing TMDL implementation rates in EPA 

Region 5................................................................................................................................................5

Figure 4-1. Comparison of estimated percent of partially to fully implemented sample TMDLs among 

sample population and subpopulations ...............................................................................................27 

Figure 4-2. Estimated percent of TMDLs in sampled subpopulations that have an implementation plan .28 

Figure 4-3. Frequency of partially to fully implemented TMDL samples associated with watershed or 

multi-TMDLs......................................................................................................................................29 

Figure 4-4. Percent of TMDL samples partly/fully implemented, reaggregated by predominant land cover 

in watershed ........................................................................................................................................30 

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TMDL Implementation Rates in EPA Region 5 Project Report 

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TMDL Implementation Rates in EPA Region 5 Project Report 

1 INTRODUCTION 

The Total Maximum Daily Load (TMDL) Program has accounted for the current listing of more than 

44,000 impaired waters nationwide and the development of more than 40,000 TMDLs since the 

Program’s inception. However, the rate of implementing TMDLs – putting into practice the onsite 

pollution controls called for in the TMDL -- long remained virtually undocumented. The TMDL Program 

was criticized in a 2007 program review by the Office of Inspector General for not being able to estimate 

the rate of implementing TMDLs in any way. The U.S. Environmental Protection Agency (EPA) 

subsequently committed to explore sample-based methods for estimating implementation rates, and 

specifically to conduct a TMDL implementation sampling pilot study in the six north-central states of 

EPA Region 5. The purpose of the study was to conduct an analysis of Regional TMDL implementation 

rates and characteristics as represented in a probabilistic sample of Region 5 TMDLs. The basic TMDL 

activities of interest in this analysis included: 

• Partial to full progress in planning, funding and installing Best Management Practices (BMPs) 

that address the Load Allocation of a given TMDL, through Section 319 (or, to the extent 

available, other) projects; 

• Partial to full progress in incorporating the Waste Load Allocations (WLAs) of a given TMDL in 

National Pollutant Discharge Elimination System (NPDES) (or other) permits; 

• Identification of each sample TMDL as part of a single-TMDL versus multiple-TMDL 

development effort; and 

• Partial to full progress in developing an Implementation Plan. 

The project analyzed a sample of approved TMDLs within Region 5 to estimate implementation status at 

the Regional level within a +/- 10 percent margin of error at 90 percent confidence. The list of TMDLs 

was extracted from the National TMDL Tracking System (NTTS) in April 2008 and contained a Region 5 

statistical universe of 2,228 TMDLs approved through FY2007. Subpopulations of interest also enabled 

the comparison of older and newer TMDLs (through FY2003 and FY2004 to 2007), and nonpoint-only 

and point source related (point-only and mixed) TMDLs. The study was not designed to obtain statelevel statistically valid results. Based on the subpopulations, desired accuracy, and desired statement 

parameters, the estimated minimum sample size was 126. Additional samples (15) were added to 

compensate for expected non-response or other data issues, yielding a sample selection of 141 TMDLs. 

Three TMDLs were subsequently deleted from the study as unsuitable samples, and the final study 

therefore included 138 TMDLs. These samples were proportionally allocated among Region 5 states; the 

single-state totals thus range from 10 to 42 TMDL samples. 

EPA determined the desired accuracy and outputs of the project, developed the project design, selected 

the sample, and prepared preliminary data about each sample. EPA also contracted with Tetra Tech, Inc. 

(Tetra Tech) to provide support for several project subtasks. Tetra Tech’s scope of effort was limited to 

developing data collection protocols, collecting the data regarding implementation, and organizing the 

data into a database. This report summarizes the approach and results of the Tetra Tech subtasks. Section 

2 summarizes the technical approach, Section 3 describes the data collection effort for each state, and 

Section 4 presents the results and observations. Definitions of key terms as they relate to this project are 

provided in Section 5. 

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TMDL Implementation Rates in EPA Region 5 Project Report 

2 TECHNICAL APPROACH 

The technical approach for each of the following three project subtasks was carried out by the Tetra Tech 

project team: 

• Subtask A: Project Work Plan and Establishment of Data Collection Protocols 

• Subtask B: Collect and Compile Field Data 

• Subtask C: Organize Findings and Develop Report 

2.1 SUBTASK A: PROJECT WORK PLAN AND ESTABLISHMENT OF DATA COLLECTION PROTOCOLS

This subtask focused on developing the project work plan, establishing the data collection protocols, and 

identifying quality assurance/quality control (QA/QC) procedures for the consistent, efficient and timely 

collection of the information identified in the statement of work (SOW). The data elements to be collected 

were documented in the SOW and serve to fill the following general data needs: 

• Identifying basic TMDL information (e.g., waterbody, pollutant, state) 

• Identifying point and nonpoint source implementation activities outlined in the TMDL (or 

Implementation Plan) 

• Determining the status of permitting and BMP implementation activities outlined in the TMDL 

(or Implementation Plan) 

• Documenting additional NPDES facilities, Section 319 projects or other nonpoint source projects 

not included in the TMDL documents 

A number of sources of information were used to collect the necessary data, including: the TMDL reports 

and decision documents; TMDL implementation plans; online web pages and databases; permit and grant 

documentation; and state TMDL, permitting and nonpoint source personnel. The data collection protocols 

identified the sources of information relevant to each data element and the priority order for their review. 

For example, the available TMDL-related reports were reviewed first for any relevant information prior to 

searching other information sources such as online databases. State personnel were not contacted until 

after analyzing the readily available reports and other sources of information and identifying the data gaps 

that required additional inquiry. This was done to eliminate any unnecessary burden on state personnel 

and to make the most efficient use of their time. 

The data collection protocols also relied on the development of a standardized Excel spreadsheet and 

Access database to compile and organize the information. The spreadsheet was used to document the 

available data as they were collected. The data were then inserted into the database to standardize data 

storage and facilitate data querying. 

For each TMDL, five categories of data were recorded in the spreadsheet: 

• Basic sample reference information 

• Preliminary TMDL-level information 

• Within-TMDL information (additional data not included in TMDL document) 

• Summary TMDL implementation data 

• Contact information 

Table 2-1 lists these five categories and the associated data elements needed for each. The process for 

obtaining and recording information for the data elements is explained in the following sections. 

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TMDL Implementation Rates in EPA Region 5 Project Report 

Table 2-1. Data elements included in each TMDL analysis form 

Basic TMDL Reference Information 

TMDL State Pollutant Description 

TMDL Sample # TMDL Type 

Waterbody Name TMDL Fiscal Year 

TMDL ID 

Preliminary TMDL-Level Information 

General Categories of PS Status of BMP Implementation 

Total WLA Status of BMP Planning 

WLA Units WLA Allocation Details 

NPDES Facility Names Other Project Names 

NPDES Facility IDs Sponsoring Sources 

NPDES Facility Type Funding 

Individual WLAs for each NPDES ID Status of Project Implementation 

Individual WLA Units WLA Allocation Details 

Status of incorporating WLAs into NPDES Permits Status of Project Planning 

Issuance/Reissuance Date Included in TMDL Report or Post-TMDL 

General Categories of NPS LA Allocation Details 

Total LA LA Units 

319 Project Names 319 Project IDs 

Year of Funding TMDL Implementation Status 

Funding Source of Funding Information 

Status of BMP Implementation Status of BMP Planning 

Source of BMP Implementation BMP Planning Source 

TMDL Implementation Plan Status Is Segment-Pollutant Combination Part of MultiTMDL/Watershed TMDL Analysis? 

What Date Did TMDL Implementation Begin? Total # of TMDLs Finalized in TMDL Document 

Within-TMDL Information (Additional Data Not Included In TMDL Document) 

NPDES Facility Names Status of BMP Planning 

NPDES Facility IDs Project Name 

NPDES Facility Type Sponsoring Sources or Permit Number 

Issuance/Reissuance Date Funding 

Status of WLA Implementation Status of Project/Permit Implementation 

319 Project Name Status of BMP Planning 

319 Project IDs Evidence of Water Quality Improvements, and Source 

Funding Data Mining Contact(s) 

Funding Source Status of BMP Implementation 

Project Implementation Source Data Mining/Compilation Issues 

Status of Project Planning Project Planning Source 

Other Project Names Sponsoring Sources 

TMDL Implementation Summary Details 

Overall TMDL Implementation Status TMDL Implementation Plan Completed? 

PS-Related Implementation Status TMDL Developed as Part of Multi-TMDL or Watershed TMDL? 

NPS-Related Implementation Status TMDL Implementation Within the Watershed but not on TMDL 

Segment 

Overall TMDL Implementation Status Up Through FY 

2003 Parallel but Unrelated Implementation 

Overall TMDL Implementation Status from FY 2004 

Through FY 2007 Evidence of Water Quality Improvements? 

Evidence Sources Data Mining Issues 

Contacts and Sources 

Contact Name Contact Phone 

Contact E mail Source 

Source Address Reason Used 

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TMDL Implementation Rates in EPA Region 5 Project Report 

2.1.1 Approved Sources of Information 

The following sources of information were used to determine the implementation status of TMDL 

samples in this study. For all of these approved sources of information, a practice was considered to have 

been implemented if it was described as currently active or having already occurred. However, when the 

source referred to future plans to implement, even when those dates had passed, secondary verification 

was required. 

• TMDL Documents or Web sites 

• Permit documents or Web sites 

• Section 319 Nonpoint Source documents or Web sites 

• Other Point Source or Nonpoint Source documents or Web sites 

• Point Source or Nonpoint Source project-related files 

• Implementation Plans 

• Other implementation studies, data systems or Web sites 

• Correspondence with State contacts 

• Correspondence with other project contacts 

2.1.2 Data Recording 

The project team determined the status of each of the data elements shown in Table 2-1 through 

reviewing available documentation and speaking to the appropriate personnel. As information was 

obtained for each data element, it was recorded in an Excel spreadsheet for each state. Once the state 

spreadsheets were fully populated the data were migrated into an Access database. 

The design of the Access database is shown in Figure 2-1. Separate tables exist for information related to 

the TMDL itself, point source controls, Section 319 nonpoint source controls, other nonpoint source 

controls, status of the implementation plan, overall implementation status, and contact information. The 

use of a database design allowed more efficient recording of information with one-to-many relationships. 

For example, one TMDL document might include 12 different point sources or two separate Section 319 

projects. By using a database design the information about the TMDL itself (e.g., state, waterbody name) 

can be recorded only once and linked to related tables instead of having to be duplicated for each record 

of related information. The use of a database also allowed for the standardization of data entries, where 

possible, through the use of “pick lists” to ensure no errors were made in recording the information. For 

example, a Yes/No pick list was used to record whether the TMDL includes an Implementation Plan. 

Similarly, the database required that certain data entries be of a certain type (e.g., all dates must be input 

in date format). Having all of the information in a database also facilitated the eventual querying of the 

data to answer the key study questions. 

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TMDL Implementation Rates in EPA Region 5 Project Report 

Figure 2-1. Structural relationship of the database for analyzing TMDL implementation rates. Lines 

connecting each table with a one and the infinity symbol imply a one-to-many relationship. 

2.1.3 Description of Source Interactions 

This section describes how the project team used various sources to obtain the desired information. 

Initial Data Elements Obtained from TMDL Documents:

The project team reviewed the final approved TMDL Document and EPA’s decision document (if 

necessary) to obtain the list of NPDES facilities in the watershed. It was also determined from the final 

TMDL document which of the facilities received WLAs resulted in a new permit limit compared to those 

where the TMDL re-affirmed the existing permit limit. 

The final TMDL document was also used to obtain a list of any Section 319 projects in the watershed. 

These were cross-referenced against data from EPA’s Section 319 Grants Reporting and Tracking System 

(GRTS) to determine if there were any other Section 319 projects relevant to the TMDL. Data from 

GRTS were obtained by querying the following Web site: 

 

http://iaspub.epa.gov/pls/grts/f?p=110:3000:8752660467639323::NO:3000:: 

Determining Status of Implementation Activities Outlined in TMDL Documents:

A thorough review of each implementation activity (permitting, Section 319 projects, and other nonpoint 

source projects) noted in the TMDL documents was completed to determine the status of actual 

implementation. The purpose of the review was to determine the extent to which any referenced 

implementation activity had actually occurred. Implementation recommendations without any specific 

evidence suggesting that they had been implemented were noted for later cross-referencing with the 

appropriate personnel. 

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TMDL Implementation Rates in EPA Region 5 Project Report 

Determining Status of WLA Implementation:

The project team reviewed available NPDES permits to determine if any changes resulting from the 

TMDL had been incorporated into the permit. Permits for some major facilities were found online in 

some states but no major or minor permits were available online in others. Finally, state personnel were 

contacted to determine the status of WLA implementation. Personal contact with state personnel proved 

to be the most frequent method for determining the status of WLA implementation. The team did not need 

to contact any permittees directly to request that they provide an update on the status of WLA 

implementation. 

Determining Status of BMP Implementation for Section 319 Projects:

The project team first searched the Internet for any documentation related to Section 319 projects known 

to exist in the TMDL watershed. Information in GRTS proved to be valuable for determining if projects 

had occurred in a TMDL watershed, but was less valuable for determining specific information about 

what projects had been implemented and where. Several states post their Section 319 annual reports 

online and these were valuable sources of information regarding the status of some Section 319 projects. 

When information about a Section 319 project was not available from the Internet, it was requested 

directly from state staff and, in a few cases, directly from the local grant recipient. The final sources of 

implementation about Section 319 projects were about equally split between online databases/reports and 

contact with state personnel or grant recipients. 

Several of the Section 319 source projects were not initiated in response to the TMDL because they did 

not focus on the TMDL pollutant, were completed more than 3 years prior to TMDL approval, or the 

practices occurred in the watershed but not upstream of the segment included in this study. The project 

team used their best judgment to determine if the Section 319 projects represented TMDL 

implementation, but the information to make a conclusive decision was often not available. 

Determining Status of BMP Implementation for Other Nonpoint Source Projects:

The project team requested information on other nonpoint source projects from state TMDL and Section 

319 staff but most of this type of information came from direct contact with local Natural Resources 

Conservation Service (NRCS) and Soil and Water Conservation District (SWCD) personnel. In a few 

cases a local watershed group was also able to provide information on non-Section 319 nonpoint source 

projects. 

Some of the challenges associated with the Section 319 projects also applied to the other nonpoint source 

projects such as difficulty determining whether practices were installed upstream of the TMDL segment 

and whether implementation occurred because of or coincident to the TMDL. As with the Section 319 

projects, the team used their best judgment to determine if the other nonpoint source projects represented 

TMDL implementation. 

Additional NPDES Facilities, Section 319 Projects, and Other Nonpoint Source Projects: 

Information on NPDES facilities, Section 319 projects, and other nonpoint source projects not listed in 

the TMDL document was found in various sources, including the TMDL Implementation Plans, the 

Section 319 annual reports, and on the Internet. All additional facilities and projects found using these 

sources were cross referenced against those found in the TMDL Documents to avoid duplication. The 

appropriate data and approved sources were recorded for each facility/project. 

Type of Permit (major, minor individual):

Tetra Tech was able to determine the type of permit (i.e., major or minor) for many of the wastewater 

treatment facilities from the TMDL document, the Permit Compliance System (PCS), the Integrated 

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TMDL Implementation Rates in EPA Region 5 Project Report 

Compliance Information System (ICIS), or the actual permit. The type of permit could not be determined 

for quite a few permits, however, and permit type is thus sometimes left blank in the database. 

Status of TMDL Implementation Plan: 

The project team first checked online to determine if any Implementation Plans were available and then 

followed-up with state TMDL and Section 319 staff. Local stakeholders were also contacted in several 

cases to request information on the existence of Implementation Plans. 

Signs of Water Quality Improvement:

This assessment’s scope of work did not include the assessment of water quality data to document signs 

of water quality improvement, although it was to be noted if discovered. The only such information that 

was identified were references to improved water quality that were made in a Section 319 Nonpoint 

Source Success Story about Governor Bond Lake in Illinois. 

2.1.4 Quality Assurance Procedures 

To collect and report accurate information for this project, Tetra Tech staff who conducted the work 

operated under the Quality Management Plan for Tetra Tech’s Fairfax Center, which is based on the 

quality system requirements of ANSI/ASQC E4-1994, Specifications and Guidelines for Environmental 

Data Collection and Environmental Technology Programs (ASQC Quality Press, Milwaukee, WI, 1994) 

and is continually updated in accordance with comments received from EPA under other contracts. The 

QMP describes quality policy and quality management organization and supports all work conducted, 

including this project. 

Specific additional quality assurance procedures that were identified and implemented for this project 

included the following: 

• All data compilation efforts were performed by Tetra Tech personnel with significant TMDL 

experience in EPA Region 5. In several cases the Tetra Tech personnel responsible for collecting 

or reviewing the necessary information actually supported the states in the development of the 

TMDL. This familiarity with each state TMDL Program, not to mention individual TMDL 

projects, reduced the likelihood that data were incorrectly recorded due to a misunderstanding of 

the issues or information. 

• Once the initial data compilation effort was completed, senior Tetra Tech personnel (not involved 

with the original compilation efforts) performed a “spot check” of 10 percent of the entries for 

each state for potential problems. If any problems were found within the first spot check, an 

additional 10 percent of the entries were reviewed and this process was repeated until no 

problems were found. 

• As described previously, the use of an Access database allowed for certain data elements to have 

prescribed “pick lists” to minimize the potential for data entry errors. 

• When speaking to state personnel, if the Tetra Tech interviewer was at all uncertain that he or she 

recorded the interviewees response correctly, the summarized findings were sent back to the 

interviewee so that they had the opportunity to make corrections. 

2.2 SUBTASK B: COLLECT AND COMPILE FIELD DATA

During Subtask B, the project team followed the protocols developed in Subtask A to obtain the necessary 

information. The project team held several internal meetings to ensure a common understanding of the 

project goals and technical approach to minimize discrepancies in data collection efforts, and also met 

regularly during data compilation activities to ensure consistency among efforts and to immediately 

identify and resolve any issues that arose. For example, during the early data collection efforts, the team 

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TMDL Implementation Rates in EPA Region 5 Project Report 

discovered watersheds where Section 319 projects had occurred before the approval of the TMDL. In 

some cases the projects pre-dated the TMDL by only a year or two, but in other cases the Section 319 

projects occurred as many as ten years prior to the TMDL. The project team met to discuss this issue and 

agreed, as a general rule, that Section 319 projects that were completed within three years of TMDL 

approval should be counted towards TMDL implementation. This was based on Tetra Tech’s experience 

that TMDLs within Region 5 typically take one to two years to be completed and thus the Section 319 

project and the TMDL effort had a good chance of overlapping one another. It was also consistent with 

the purpose of the study, which was to determine if the terms of the TMDLs are being implemented, not 

whether the TMDLs prompted implementation after finalization. 

To optimize data collection activities and to meet the project schedule, the project team distributed data 

collection responsibilities by state. Each state lead identified the information needed from TMDLs in his 

or her assigned state and was responsible for collecting and compiling the information. 

In general, the project team initiated all data compilation activities by trying to obtain the necessary data 

from the TMDL document, EPA decision document, and/or Implementation Plan (when available). 

Information not available from these three sources was next searched for in publicly accessible federal or 

state databases such as PCS, ICIS, and GRTS, as well as through general searches on the Internet. 

Once each of these sources had been searched, the project team requested missing information from state 

personnel. The approach for contacting the state personnel was determined through conversations with 

the following TMDL coordinators in each of the six Region 5 states: 

• Illinois EPA (IEPA): Dean Studer 

• Indiana Department of Environmental Management (IDEM): Andrew Pelloso 

• Michigan Department of Environmental Quality (MDEQ): Brenda Sayles 

• Minnesota Pollution Control Agency (MPCA): Jeff Risberg 

• Ohio EPA: Trinka Mount 

• Wisconsin Department of Natural Resources (WNDR): Nicole Richmond 

Illinois and Indiana directed the project team to work with individual personnel with expertise in various 

subject areas (e.g., NPDES permitting, Section 319 projects). Michigan and Wisconsin provided a central 

point-of-contact who obtained much of the data directly. TMDL implementation data for Minnesota were 

obtained from several state Web sites and through conversations with MPCA personnel. For the TMDLs 

in Ohio some of the necessary information on point sources and nonpoint source implementation 

activities was available from Dr. John Hoornbeek of Kent State University who had recently conducted a 

similar study for EPA. 

Information not available from federal or state databases or state personnel was requested from persons 

responsible for the actual implementation in each watershed (subject to approval from the state TMDL 

coordinators). This included SWCD personnel, NRCS personnel, and watershed coordinators. 

2.3 SUBTASK C: ORGANIZE FINDINGS AND DEVELOP REPORT

Upon completion of the data collection and compilation into an organized format, the project team 

prepared this project report that documents the data collection process and results. 

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TMDL Implementation Rates in EPA Region 5 Project Report 

3 STATE SUMMARIES 

This section of the report provides a summary by state of the data collection effort. As specified in the 

SOW, state-level results are not presented; rather, the section describes the general process used to gather 

the information for each state and identifies any unique issues that were encountered. 

3.1 ILLINOIS TMDL SUMMARY

Implementation efforts for a total of 18 Illinois TMDLs (eight lakes and ten streams) were assessed as 

part of this study (Table 3-1). All of the 18 Illinois waterbodies were listed as impaired by nonpoint 

sources of pollution. In addition, seven of the 18 TMDLs included WLAs for point sources. Two of the 

Illinois TMDLs are for fecal coliform, four are for manganese, three are for nitrates, four are for 

phosphorus, two are for total suspended solids, and one each are for siltation, sulfate, and total dissolved 

solids. All of the 18 Illinois TMDLs were developed as part of a multi- or watershed-TMDL, and all but 

one have some form of an Implementation Plan completed. Most of the TMDLs (15 of 18) were 

developed after 2003. 

Table 3-1. Summary of Illinois TMDLs. 

TMDL Sample 

Number TMDL ID Waterbody Name Pollutant TMDL Type TMDL Fiscal Year 

Sample 010 33628 Argyle Lake Total Phosphorus Nonpoint Source 2007 

Sample 016 33163 N. Fk. Mauvaise Terre 

Creek Manganese Nonpoint Source 2007 

Sample 021 31540 Homer Lake Phosphorus Nonpoint Source 2006 

Sample 024 3836 Governor Bond Lake Total Susp. Solids Point/Nonpoint Source 2002 

Sample 031 33973 E. Fk. Kaskaskia River Total Susp. Solids Nonpoint Source 2003 

Sample 034 12240 Kinmundy New Lake Manganese Nonpoint Source 2005 

Sample 038 10834 Big Muddy River Sulfate Nonpoint Source 2004 

Sample 050 31659 N. Fk. Kaskaskia River Manganese Nonpoint Source 2006 

Sample 075 33700 Salt Fk. Vermilion River Nitrates Point/Nonpoint Source 2007 

Sample 081 3832 Governor Bond Lake Non-Volatile 

Suspended Solids Point/Nonpoint Source 2002 

Sample 084 33632 North Fk. Cox Creek Total Diss. Solids Nonpoint Source 2007 

Sample 088 12250 Paris Twin West Phosphorus Nonpoint Source 2005 

Sample 099 12283 Flat Branch Fecal Coliform Point/Nonpoint Source 2005 

Sample 100 33201 N. Fk. Vermilion River Nitrates Nonpoint Source 2007 

Sample 117 12321 Old Lake Hillsboro Phosphorus Nonpoint Source 2005 

Sample 121 33564 Little Wabash River Manganese Point/Nonpoint Source 2007 

Sample 126 33163 Mauvaisse Terre Lake Nitrate Nonpoint Source 2006 

Sample 127 12283 Sugar Creek Fecal Coliform Point/Nonpoint Source 2005 

3.1.1 Point Source Implementation 

None of the TMDLs and associated WLAs recommended revised effluent limits for the NPDES permits. 

For several of the TMDLs the state determined that water quality standards could be met without 

additional reductions in point source loadings; therefore, all the WLAs were set equal to the loading rates 

specified by existing NPDES permits. In other cases, when the nonpoint source loads were compared to 

9
TMDL Implementation Rates in EPA Region 5 Project Report 

the point source loads, the NPDES facilities were determined to represent a negligible portion of the 

overall load and did not receive an explicit WLA (which equates to a WLA of zero). 

 

Several of the Illinois TMDLs recommended that point sources begin conducting additional monitoring 

so that their impact on the impaired waterbody could be better understood. This requirement was added to 

several of the permits, but for several permits it was not, apparently due to a lack of communication 

between TMDL and NPDES staff. Dean Studer of the Illinois EPA provided the following information 

regarding the state’s efforts to integrate TMDL results into the permitting process: 

“...I am in the process of developing memos and notification to IEPA permit staff so that 

appropriate conditions can be included in NPDES permits where a TMDL has been 

approved. Our goal is to develop the process by 12/31/2008. After which we will start 

with the most currently approved TMDLs working our way back through to the older 

TMDLs and indicate in memos to permit staff (and notification to the discharger) of what 

should be included in the next NPDES permit for these facilities.” 

3.1.2 Nonpoint Source Implementation 

Clean Water Act Section 319 projects were found in 10 of the 18 Illinois TMDL watersheds. However, 

several of these were not initiated in response to the TMDL because they did not focus on the TMDL 

pollutant or were completed as early as ten years prior to TMDL approval. Section 319 projects that were 

completed within three years prior to TMDL approval were counted towards TMDL implementation if 

the practices matched the pollutant of concern. Of the 10 watersheds with completed 319 projects, six had 

completed projects that were counted towards TMDL implementation. One waterbody (Governor Bond 

Lake, TSS) was removed from the Section 303(d) list after the Section 319 projects successfully mitigated 

the impairment. This was the only Illinois TMDL considered fully implemented. 

Local SWCD personnel were also contacted to request information on implementation activities and 

several of them reported that a number of practices were in place within each watershed to improve water 

quality. However, it appeared that much of the implementation was occurring independent of the TMDL 

through ongoing U.S. Department of Agriculture programs such as the Conservation Practices Program 

(CPP), Conservation Reserve Program (CRP), and the Environmental Quality Incentives Program (EQIP). 

In these situations the practices were still counted towards TMDL implementation if they addressed the 

pollutant of concern and were occurring during or after approval of the TMDL. This is an important point 

that is discussed in more detail in Section 5. 

3.1.3 Information Sources 

A summary of all the Web sites that were accessed to obtain information on the Illinois TMDLs is 

provided in Table 3-2. The list of state and local contacts is provided in Table 3-3. 

10
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-2. Summary of online sources of implementation data. 

Agency Web Site Address Summary of Information 

Obtained 

IEPA http://www.epa.state.il.us/water/watershed/reports/biannual-319/ Section 319 grant information 

and project summaries 

IEPA http://www.epa.state.il.us/water/tmdl/

Information on implementation 

projects, TMDL Documents 

and Implementation Plans 

IEPA http://www.epa.state.il.us/water/conservation-2000/index.html

Information on Conservation 

2000 projects and Priority 

Watershed Projects 

County SWCDs http://www.aiswcd.org/Guide/links.htm

SWCD programs, projects, 

education, and other 

implementation efforts 

US EPA http://iaspub.epa.gov/pls/grts/f?p=110:1:4642271311943480::NO:::

Section 319 Grants Reporting 

and Tracking System (GRTS)- 

319 project information 

US EPA http://www.epa.gov/nps/success/

Additional information on 319 

projects, specifically for 

Governor Bond Lake 

IEPA, IDNR, 

and University 

of Illinois 

Extension 

http://www.watershed.uiuc.edu/getting_involved/group_search.cfm Watershed group contact 

information 

Table 3-3. List of state and local contacts. 

Agency Contact Person Information Obtained 

IEPA Dean Studer NPDES permitting details and 319 project details 

Shelby Co. SWCD Gene Davis NPS implementation activities occurring in Shelby county 

Macon Co. SWCD Shannon Allen NPS implementation activities occurring in Macon county 

Sangamon Co. SWCD Terri Nichols NPS implementation activities occurring in Sangamon county 

Montgomery Co. SWCD CJ Liddell NPS implementation activities occurring in Montgomery county 

Marion Co. SWCD Burke Davies NPS implementation activities occurring in Marion county 

Clinton Co. SWCD Annette Ambuehl NPS implementation activities occurring in Clinton county 

Randolph Co. SWCD Micky Clark NPS implementation activities occurring in Randolph county 

Perry Co. SWCD Martha Stein NPS implementation activities occurring in Perry county 

Jackson Co. SWCD Michelle Sullivan NPS implementation activities occurring in Jackson county 

Morgan Co. SWCD Jill Keeton NPS implementation activities occurring in Morgan county 

3.2 INDIANA TMDL SUMMARY

Implementation efforts for a total of 18 Indiana TMDLs were assessed as part of this study (Table 3-4). 

All of the Indiana waterbodies were listed in the National TMDL Tracking System (NTTS) as impaired 

by both point and nonpoint sources. However, further evaluation showed that three TMDL segments do 

not have any point sources upstream of them (Samples 037, 107, and 139). Fifteen of the Indiana TMDLs 

are for pathogens/E. coli while the other three are for phosphorus. All of the Indiana TMDLs addressed 

by this study were approved after 2003 and 13 of the TMDLs were approved in 2006 or 2007. All of the 

Indiana TMDLs were part of a multi-TMDL or watershed TMDL document. 

11
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-4. Summary of Indiana TMDLs. 

TMDL Sample 

Number 

TMDL 

ID Waterbody Name Pollutant TMDL Type TMDL Fiscal Year 

Sample 004 12102 White River E. coli Point/Nonpoint 

Source 2005 

Sample 019 31036 Jacks Defeat Creek E. coli Point/Nonpoint 

Source 2006 

Sample 022 30999 Wabash River Mainstem E. coli Point/Nonpoint 

Source 2006 

Sample 030 12102 White River E. coli Point/Nonpoint 

Source 2005 

Sample 037 32647 Middle Fork East Fork 

Whitewater River (Upstream) E. coli Nonpoint Source 2007 

Sample 039 31567 Junk Ditch And Other Tribs E. coli Point/Nonpoint 

Source 2006 

Sample 046 11589 Indian Creek E. coli Point/Nonpoint 

Source 2005 

Sample 047 31567 St. Marys River Trib E. coli Point/Nonpoint 

Source 2006 

Sample 051 30999 Wabash River Mainstem E. coli Point/Nonpoint 

Source 2006 

Sample 057 31036 Beanblossom Creek E. coli Point/Nonpoint 

Source 2006 

Sample 062 11316 Eel River E. coli Point/Nonpoint 

Source 2005 

Sample 074 30999 Wabash River E. coli Point/Nonpoint 

Source 2006 

Sample 091 30999 Wabash River And Tributary Phosphorus Point/Nonpoint 

Source 2006 

Sample 107 12102 Raccoon Creek-Little 

Raccoon Creek E. coli Nonpoint Source 2005 

Sample 120 30999 Wabash River Mainstem Phosphorus Point/Nonpoint 

Source 2006 

Sample 122 30999 Wabash River Phosphorus Point/Nonpoint 

Source 2006 

Sample 137 30999 Wabash River E. coli Point/Nonpoint 

Source 2006 

Sample 139 32647 West Fork East Fork 

Whitewater River E. coli Nonpoint Source 2007 

3.2.1 Point Source Implementation 

The Indiana TMDLs addressed point sources of pathogens and phosphorus. Point sources of pathogens 

included wastewater treatment plants, municipal separate storm sewer system (MS4) communities, 

combined sewer overflows (CSO), and sanitary sewer overflows (SSOs). Several of the pathogen TMDLs 

resulted in new permit limits for wastewater treatment plants, and IDEM reported that all of these have 

been implemented. Other TMDLs made allocations to CSOs and referenced that the CSO allocations 

would be addressed during the preparation and implementation of Long Term Control Plans (LTCPs). 

Some CSO implementation efforts were found to have already occurred, but most communities are still in 

the process of preparing the LTCPs, and no implementation has occurred. Similarly, work is still 

underway to eliminate existing SSOs, and Indiana MS4 communities are still in a data gathering stage. 

The MS4 and SSO WLAs specified in the TMDLs have therefore not yet been incorporated into permits. 

12
TMDL Implementation Rates in EPA Region 5 Project Report 

Point sources of phosphorus in these TMDLs also included wastewater treatment plants, MS4 

communities, CSOs, and SSOs. Although phosphorus WLAs were specified in the TMDLs, the 

permittees are first being asked to monitor and report phosphorus. Therefore implementation for point 

sources of phosphorus has not yet occurred and these sources were categorized as “not implemented” for 

the purposes of this study. 

3.2.2 Nonpoint Source Implementation 

There are several programs in place in Indiana that can be used to implement nonpoint source control 

practices. These include Clean Water Act Section 205 and 319 programs, the Lake and River 

Enhancement (LARE) program, and the various USDA programs (e.g., CPP, CRP, EQIP). 

The project team learned upon contacting IDEM for this study that it had recently completed a review of 

its Section 205 and 319 grants for use in their 2007 annual report. Some of the information needed for this 

project was therefore available from this review. The results indicated that there were 13 Section 319 

projects that addressed TMDL segments included in this study. Most of these projects are in the planning 

phase, however, and have not yet started implementation. Three of the Section 319 projects have resulted 

in implementation; however the practices for two of these did not focus on the pollutant included in this 

study. 

The team also found that there are seven other implementation efforts going on within the TMDL 

watersheds. However, similar to the Section 319 projects, most of these efforts are only in the planning 

phase, and there has not yet been any implementation. 

It should be noted that 13 of the 18 TMDLs being studied by this project were from 2006 and 2007, 

which might explain why so many are still in the planning phase. 

3.2.3 Information Sources 

A summary of all the Web sites that were accessed to obtain information on the Indiana TMDLs is 

provided in Table 3-5. The list of state and local contacts is provided in Table 3-6. 

Table 3-5. Summary of online sources of implementation data. 

Agency Web Site Address Information Obtained 

IDEM http://www.in.gov/idem/4342.htm Implementation grant information 

and project summaries 

IDEM http://www.in.gov/idem/files/2007_nonpoint_annual_report_final.pdf Information on implementation 

projects and Implementation Plans 

IDEM http://www.in.gov/idem/5233.htm Section 319 grant information and 

project summaries 

EPA http://iaspub.epa.gov/pls/grts/f?p=110:1:4642271311943480::NO::: 

Section 319 Grants Reporting and 

Tracking System (GRTS)- 319 

project information 

13
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-6. List of state and local contacts. 

Agency Contact Person Summary of Information Obtained 

IDEM Staci Goodwin NPDES permitting details 

IDEM Ernest Johnson 319 Projects 

IDEM Angie Brown NPS implementation activities 

IDEM Bonny Elfiritz NPS implementation activities 

IDEM Linda Schmidt NPS implementation activities 

3.3 MICHIGAN TMDL SUMMARY

Implementation efforts for a total of 15 Michigan TMDLs were assessed as part of this study, and the 

majority were approved prior to 2004 (Table 3-7). Only one was part of a multi-TMDL project and 11 

were for pathogens or E. coli. The other four TMDLs were for sediment, mercury, and polychlorinated 

biphenyls (PCBs). 

Table 3-7. Summary of Michigan TMDLs. 

TMDL Sample 

Number 

TMDL 

ID Waterbody Name Pollutant TMDL Type TMDL Fiscal Year

Sample 002 3843 Kawkawlin River PCBs Nonpoint Source 2002 

Sample 012 12239 River Raisin E. coli Point/Nonpoint Source 2005 

Sample 017 3847 Saline River E. coli Point Source 2003 

Sample 035 3838 Coldwater River Sediment Nonpoint Source 2001 

Sample 043 4156 Pratville Drain & Lime 

Lake E. coli Point/Nonpoint Source 2003 

Sample 044 3841 Hammell Creek Mercury Nonpoint Source 2002 

Sample 045 3844 Lenawee County Drain 

No.70 E. coli Nonpoint Source 2002 

Sample 048 4271 Wagner-Pink Drain E. coli Nonpoint Source 2003 

Sample 087 12277 Unnamed Tributary To 

Grand River Sediment Point/Nonpoint Source 2005 

Sample 096 3658 Galien River E. coli Point/Nonpoint Source 2002 

Sample 106 3842 Huron River E. coli Point/Nonpoint Source 2001 

Sample 108 32213 Albrow Creek E. coli Nonpoint Source 2007 

Sample 112 4270 Shiawassee River E. coli Nonpoint Source 2003 

Sample 113 9499 Grand River And Portage 

River E. coli Point/Nonpoint Source 2003 

Sample 133 3840 Deer Creek E. coli Point/Nonpoint Source 2002 

3.3.1 Point Source Implementation 

Point sources of pathogens addressed in these TMDLs included a confined animal feeding operation 

(CAFO), wastewater treatment plants, construction activities, and industrial stormwater. In Michigan 

waterbodies are listed for E. coli impairments, and WLAs are set to E. coli standards. However, NPDES 

permits in Michigan are for fecal coliform with an assumption that a fecal coliform limit of 200 

counts/100 mL will result in E. coli standards being met. All of the WLAs for wastewater treatment 

facilities have been incorporated into the required permits. Additionally, all of the industrial and 

construction permits have the required fecal coliform limits. The only CAFO involved with one of the 

14
TMDL Implementation Rates in EPA Region 5 Project Report 

Michigan TMDLs is not permitted to discharge, and implementation was therefore considered to have 

occurred. 

One of the sediment TMDLs allocated to three different MS4 communities and Michigan DEQ indicated 

that all three communities are meeting their WLAs (which the TMDL specified would be expressed as 

TSS limits and/or flow volume limitations). 

3.3.2 Nonpoint Source Implementation 

Nonpoint sources for the Michigan TMDLs include agricultural runoff, non-permitted urban runoff, muck 

farming land uses, road crossings, abandoned mine discharge, pet and wildlife feces, septic systems, 

atmospheric deposition, and degraded riparian areas. 

Sixteen Section 319 projects were found for the Michigan TMDLs included in the study, and most of 

these were initiated in response to the TMDL and resulted in implementation. For example, within the 

Huron River watershed several Section 319 projects were used to eliminate illicit sewer connections by 

rerouting sanitary leads to sanitary sewers. 

Fourteen other nonpoint source implementation projects were found for the Michigan TMDLs included in 

this study. These included several Clean Michigan Initiative Clean Water Fund projects as well as 

projects funded by municipalities to address failing septic systems or sewer improvement projects. Three 

of these projects resulted in full implementation as described below: 

• Sample 106 is an E. coli TMDL for Geddes Pond along the Huron River. Four Section 319 

projects have resulted in the installation of various practices to implement this TMDL. One 

project implemented an Illicit Discharge Elimination Plan to detect and correct non-storm water 

discharges, including bacteria. As part of this project, more than 100 manholes, waterways and 

outfalls were sampled, eight subwatersheds were investigated, and video inspections were 

performed in two subwatersheds. The other projects re-routed sanitary leads to sanitary sewers. It 

is estimated that as a result of this project, a minimum of 141,000 thousand gallons of sanitary 

wastewater were removed from the storm sewer network annually. The City of Ann Arbor and 

the University of Michigan also hold stormwater permits that outline specific requirements for 

controlling their discharge of E. coli to Geddes Pond in accordance with the TMDL. 

• Sample 045 is an E. coli TMDL for Lenawee County Drain No. 70. The only source of E. coli to 

this drain was found to be an unsewered subdivision in Palmyra Township. The township passed 

a resolution, dated January 23, 2002, to design and construct a regional treatment plant with 

neighboring Madison Township. The plant was built, the subdivision was connected to a sanitary 

sewer system, and the newly constructed WWTP discharges to the Raisin River, removing the 

source of pollution to Lenawee County Drain No. 70. 

• Sample 043 is an E. coli TMDL for Prattville Drain and Lime Lake. There is one CAFO located 

upstream of the impaired segment that was considered a significant source of the E. coli; MDEQ 

reports that it has been addressed through a revised permit. An unsewered area of the City of 

Prattville was the other significant source of E. coli and it was connected to sanitary sewers since 

the TMDL was completed. 

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TMDL Implementation Rates in EPA Region 5 Project Report 

3.3.3 Information Sources 

A summary of all the Web sites that were accessed to obtain information on the Michigan TMDLs is 

provided in Table 3-8. The list of state and local contacts is provided in Table 3-9. Christine Alexander of 

MDEQ provided much of the information required for the Michigan TMDLs by following up with other 

MDEQ personnel regarding NPDES permits and nonpoint source projects. 

Table 3-8. Summary of online sources of implementation data. 

Agency Web Site Address Summary of Information 

Obtained 

MDEQ http://www.michigan.gov/deq/0,1607,7-135-

3313_3682_3714_31581-104272--,00.html

Coldwater River 

Implementation Information 

MDEQ http://www.michigan.gov/documents/deq/ess-nps-wmpcoldwater-part1_210565_7.pdf

Coldwater River Watershed 

Management Plan 

MDEQ http://www.michigan.gov/deq/0,1607,7-135-3308_3323-75185--

,00.html

Additional Implementation 

Information 

MDEQ http://www.michigan.gov/deq/0,1607,7-135-

3313_3682_3714_31581-104363--,00.html

Upper Grand River Watershed 

Management Plan 

MDEQ http://www.deq.state.mi.us/csosso

DEQ CSO and SSO Discharge 

Information to determine permit 

limits 

MDEQ http://www.deq.state.mi.us/documents/deq-water-npdesbulletins-Mar_05.pdf

Monthly Water Bulletin-Used to 

obtain permit information 

MDEQ http://www.michigan.gov/documents/deq/wb-npdes-bulletinsJuly2007_202961_7.pdf Stormwater Permit Information 

MDEQ http://www.michigan.gov/deq/0,1607,7-135-

3313_3682_3714_4012-95955--,00.html

List of Approved Watershed 

Management Plans 

MDEQ http://www.deq.state.mi.us/part201ss/

Information on possible PCB 

implementation within the 

Kawkawlin River Watershed 

River Raisin 

Watershed 

Council 

(RRWC) 

http://riverraisin.org/about/management_plan.html River Raisin Watershed 

Management Plan 

Table 3-9. List of state and local contacts. 

Agency Contact Person Information Obtained 

MDEQ Christine Alexander NPDES permitting details, 319 Grant Project 

Implementation Details, Additional Implementation Details 

3.4 MINNESOTA TMDL SUMMARY

Implementation efforts for 27 Minnesota TMDLs were assessed as part of this study (Table 3-10). Of the 

total, 21 were developed as part of Minnesota’s statewide mercury TMDL. In addition to the 21 mercury 

TMDLs, three of the listed segments were for fecal coliform as part of a larger southeast Minnesota 

regional TMDL, two were for biochemical oxygen demand (BOD) as part of a watershed TMDL, and one 

was for sediment. 

With respect to the mercury TMDLs, major sources of mercury to Minnesota’s waters are the result of 

atmospheric deposition. Implementation efforts associated with this TMDL are largely focused on 

emission reductions from coal-fired power plants and mercury minimization. Because of difficulties in 

16
TMDL Implementation Rates in EPA Region 5 Project Report 

assigning air emission point sources to individual mercury TMDLs, this review focused on point sources 

associated with wastewater discharges holding NPDES permits. 

17
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-10. Summary of Minnesota TMDLs. 

TMDL 

Sample 

Number 

TMDL 

ID Waterbody Name Pollutant TMDL Type 

TMDL 

Fiscal 

Year 

Sample 009 32413 Rainy River -- Rapid River to Baudette 

River Mercury Point/Nonpoint Source 2007 

Sample 011 32413 Little Fork River -- Beaver Brook to Rainy 

River Mercury Point/Nonpoint Source 2007 

Sample 013 32413 Murphy Lake Mercury Nonpoint Source 2007 

Sample 015 2007 Mississippi -- Upper St. Anthony Falls to 

Lower St. Anthony Falls Mercury Nonpoint Source 2007 

Sample 018 32413 Snowbank Lake Mercury Nonpoint Source 2007 

Sample 033 32413 Dam Five Lake Mercury Nonpoint Source 2007 

Sample 040 3867 S.F. Zumbro River -- Cascade Creek to 

Zumbro Lake Fecal Coliform Point/Nonpoint Source 2006 

Sample 053 32413 Pit Lake Mercury Nonpoint Source 2007 

Sample 055 2007 Le Homme Dieu Mercury Nonpoint Source 2007 

Sample 064 32413 Benson Lake Mercury Nonpoint Source 2007 

Sample 067 32413 Clearwater Lake Mercury Nonpoint Source 2007 

Sample 068 3867 Rush Creek -- Headwaters to Straight 

River Fecal Coliform Nonpoint Source 2006 

Sample 071 2007 Lake Harriet Mercury Nonpoint Source 2007 

Sample 077 32413 Rainy River -- Iron Lake to Lac la Croix Mercury Nonpoint Source 2007 

Sample 082 32033 Otter Tail River -- Breckenridge Lake to 

Bois de Sioux River 

Sediment (TMDL 

for Turbidity) Nonpoint Source 2007 

Sample 083 12278 Long Prairie River -- Fish Trap Creek to 

Crow Wing River CBOD; NBOD Nonpoint Source 2005 

Sample 089 2007 Blue Earth River -- Center Creek to Elm 

Creek Mercury Point/Nonpoint Source 2007 

Sample 093 2007 French Lake Mercury Nonpoint Source 2007 

Sample 095 2007 Artichoke Lake Mercury Nonpoint Source 2007 

Sample 102 3867 Garvin Brook -- Class 1B, 2A, 3B portion Fecal Coliform Point/Nonpoint 

Source 2006 

Sample 111 32413 Sandy Lake Mercury Nonpoint Source 2007 

Sample 118 32413 Greenwood Lake Mercury Nonpoint Source 2007 

Sample 125 32413 Little Iron Lake Mercury Nonpoint Source 2007 

Sample 128 2007 Mississippi River -- Watab River to Sauk 

River Mercury Point/Nonpoint Source 2007 

Sample 134 32413 Potato Lake Mercury Nonpoint Source 2007 

Sample 138 32413 Rabbit Lake (East Portion) Mercury Nonpoint Source 2007 

Sample 141 12278 Long Prairie River -- Turtle Creek to 

Moran Creek CBOD; NBOD Nonpoint Source 2005 

Further evaluation showed that many of the mercury TMDLs identified in NTTS as point/nonpoint source 

TMDLs actually do not have NPDES permits on the listed segments. In addition, one of the non-mercury 

TMDLs listed as nonpoint source only has an NPDES discharge to the segment. The end result is that 

only six of the TMDLs are affected by both point and nonpoint sources, while the remaining 21 are 

nonpoint source only. All of the Minnesota TMDLs addressed by this study were written after 2003. Five 

18
TMDL Implementation Rates in EPA Region 5 Project Report 

of the TMDLs were from reports approved in 2005 and 2006. The 21 mercury TMDLs and one of the 

non-mercury TMDLs were approved in 2007. 

3.4.1 Point Source Implementation 

Point sources of pathogens for the Minnesota TMDLs included NPDES facilities, MS4 communities, and 

CAFOs. WLAs for NPDES facilities were established at existing permit levels. Minnesota has deemed 

that CAFOs are not permitted to discharge. WLAs for these facilities were set equal to zero. Minnesota 

MS4 communities are required to meet WLAs under their permit and the WLAs are established as load 

limits. Each MS4 community is required to review the adequacy of its Storm Water Pollution Prevention 

Program (SWPPP). Modification of the SWPPP is required if it is not meeting the WLA. Full 

implementation for point sources of bacteria in these TMDLs is occurring. 

Point sources in the mercury TMDLs included NPDES facilities (point source emissions are discussed in 

the preceding section). It is unknown whether implementation has occurred for these facilities. 

3.4.2 Nonpoint Source Implementation 

The Minnesota TMDLs reviewed for implementation addressed nonpoint sources of sediment, oxygen 

demanding material, pathogens, and mercury. There are several programs in place in Minnesota that are 

used to address nonpoint sources. Included are the programs funded by Section 319, programs 

administered by NRCS, and programs supported by the Minnesota Clean Water Legacy Act (CWLA). 

Many of these programs also require local support, either through matching funds or in-kind services. 

In addition to the MPCA, the Minnesota Board of Water and Soil Resources (BW&SR) also plays a lead 

role in supporting nonpoint source TMDL implementation across the state. Both agencies post annual 

reports on their Web sites, providing detailed descriptions and summarizing the current status of statefunded projects. These reports served as the major source of information for this project. 

There are 12 Section 319 projects that address the non-mercury TMDL segments. A number of these 

projects covered multiple segments because the TMDLs were developed across an entire watershed or 

region. Several Section 319 projects were also extensions of efforts initiated prior to completion of the 

TMDL. For these projects, the pre-TMDL effort generally included the planning phase. This enabled 

post-TMDL work to focus on actual implementation. Each of the projects is targeted specifically towards 

pollutant reductions for the TMDL parameters and all six of the non-mercury TMDLs were considered 

partially implemented. 

There are six funded CWLA projects that address the non-mercury TMDL segments. Funding levels for 

these projects are generally larger than the Section 319 projects. In addition to financial support through 

BW&SR, some project funding also comes through other state agencies (e.g., the Minnesota Department 

of Agriculture, the Minnesota Department of Natural Resources) and from local match requirements. As 

with the Section 319 work, these projects typically cover multiple segments to address TMDLs that were 

developed across an entire watershed or region. 

3.4.3 Information Sources 

MPCA and BW&SR reports available from their Web sites provided data on each project, as well as a 

summary of current status. Web sites that were accessed are provided in Table 3-11. Once all of the 

available implementation data was obtained from the TMDL documents, Implementation Plans, 

supplemental reports, and online sources, Minnesota’s TMDL Coordinator was contacted to review the 

information (Table 3-12). 

19
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-11. Summary of online sources of implementation data. 

Agency Web Site Address Information Obtained 

http://www.pca.state.mn.us/publications/wq-iw5-02c.pdf

http://www.pca.state.mn.us/publications/wq-iw8-01c.pdf

http://www.pca.state.mn.us/publications/wq-iw9-02c.pdf

MPCA 

http://www.pca.state.mn.us/publications/wq-iw1-19.pdf

TMDL Implementation 

Plans 

MPCA http://www.pca.state.mn.us/water/cwp-319.html#reports

319 & Clean Water 

Partnership Annual 

Reports 

http://www.bwsr.state.mn.us/CWL/restoration/07R6_8R03_Wilken.pdf

http://www.bwsr.state.mn.us/CWL/restoration/07R16_b.pdf

http://www.bwsr.state.mn.us/CWL/restoration/07R14.pdf

MBW&SR 

http://www.bwsr.state.mn.us/CWL/restoration/07R118_8R1_8R33.pdf

Implementation Project 

Fact Sheets 

County SWCD http://www.mn.nrcs.usda.gov/partnerships/todd/cwp.htm SWCD Plans 

Table 3-12. List of state and local contacts. 

Agency Contact Person Summary of Information Obtained 

MPCA Jeff Risberg Review of compiled TMDL implementation data 

3.5 OHIO TMDL SUMMARY

Implementation efforts for a total of 42 Ohio TMDLs were assessed as part of this study (Table 3-13). 

Twenty-seven of the TMDLs were listed in NTTS as point/nonpoint TMDLs, nine were listed as nonpoint 

source TMDLs, and six were listed as point source TMDLs. Further investigation determined that four 

TMDLs categorized as point/nonpoint source (Samples 042, 027, 58, and 123) did not include WLAs 

because there are no regulated sources upstream of the impaired segments. These were therefore corrected 

to be nonpoint source TMDLs. In addition, TMDL samples 36 and 54 were categorized as point source 

TMDLs but include LAs. These were re-categorized as point/nonpoint TMDLs. 

Twenty-four of the TMDLs were approved before 2004 and the remaining 18 were approved between 

2004 and 2007. All the TMDLs were developed as part of a multi-TMDL project. Eight of the TMDLs 

were written for sediment; seven for phosphorus; four for nutrients; five for nitrogen; three each for 

metals, siltation and acid; two each for suspended sediment, habitat alteration and fecal coliform; and one 

each for pH, aluminum, and aldrin. All four of the “nutrient” TMDLs listed in Table 3-13 were written for 

phosphorus. 

3.5.1 Point Source Implementation 

Many of the Ohio TMDLs confirmed that water quality standards could be met without additional 

reductions in point source loadings and were thus considered fully implemented. Of those TMDLs for 

which one or more WLA indicated a need for reductions in loading from a point source, NPDES effluent 

limits consistent with these WLAs have been adopted (primarily for total phosphorus). The only one that 

was not was in the process of drafting the permit. Several TMDLs were considered as partially 

implemented for point sources because the TMDL included WLAs for CSOs in addition to wastewater 

treatment facilities and no implementation for the CSOs had as yet occurred. 

20
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-13. Summary of Ohio TMDLs. 

TMDL TMDL 

ID Sample 

Number 

Waterbody Name Pollutant TMDL Type TMDL 

Fiscal Year

10875 001 Upper Auglaize Watershed 

(Flat Fork) Sediment Nonpoint Source 2004 

9664 005 Duck Ck (Road Fork) Siltation Nonpoint Source 2003 

4292 014 Massies Creek To Beaver 

Creek Phosphorus Point/Nonpoint Source 2002 

12248 020 Snake Hollow Acid Nonpoint Source 2005 

4292 023 Anderson Fork (Grog Run To 

Caesar Creek Lake) Phosphorus Nonpoint Source 2002 

9664 026 Duck Ck (Road Fork) Suspended Solids Nonpoint Source 2003 

4172 027 Sandy Creek (L. Sandy Creek 

To Nimishillen Creek) 

Metals (Other Than 

Mercury) Nonpoint Source 2003 

12248 028 Whitmore Cemetery Acid Nonpoint Source 2005 

3898 036 Trib. To S. Fk. Sugar Creek 

(Rm 14.15) Nitrogen Point/Nonpoint Source 2003 

9664 041 Duck Ck (Greasy Run) Suspended Solids Nonpoint Source 2003 

4169 042 Brushy Fork Metals (Other Than 

Mercury) Nonpoint Source 2003 

3894 054 Sugar Creek (Headwaters To 

Middle Fork Sugar Cr.) Sediment Point/Nonpoint Source 2003 

4172 058 Lake Hope Metals (Other Than 

Mercury) Nonpoint Source 2003 

33671 059 Beaver Creek (Grand Lake St. 

Marys And Tributaries) Fecal Coliform Nonpoint Source 2007 

3894 060 Indian Trail Creek (Sugar 

Creek) Nitrogen Point/Nonpoint Source 2003 

11014 061 Wabash River Nitrate+nitrite and 

total phosphorus Point/Nonpoint Source 2004 

9446 070 Middle Fork (Sugar Creek) Sediment Point/Nonpoint Source 2003 

9446 072 Brush Run (Sugar Creek) Phosphorus Point/Nonpoint Source 2003 

10878 076 Cuyahoga River Watershed 

(Sawyer Brook) Phosphorus Point/Nonpoint Source 2004 

9664 078 Duck Ck (Mare Run) Siltation Nonpoint Source 2003 

3868 079 Little Beaver Creek Phosphorus Point/Nonpoint Source 2002 

9664 086 Duck Ck (East Fk. Duck Ck 

Trib Rm 4.15) Siltation Nonpoint Source 2003 

3868 090 Flat Fork Phosphorus Nonpoint Source 2002 

22900 094 Car Bailey Run Sediment Nonpoint Source 2006 

9562-

9563 097 Powers Brook Fecal Coliform Nonpoint Source 2003 

12274 098 Culver Creek Phosphorus Nonpoint Source 2005 

12248 101 Salem Hollow Aluminum Nonpoint Source 2005 

21
TMDL Implementation Rates in EPA Region 5 Project Report 

22

TMDL 

ID 

TMDL 

Sample 

Number 

Waterbody Name Pollutant TMDL Type TMDL 

Fiscal Year

9562-

9563 103 Cuyahoga River (Tinkers Creek To Big Creek) Phosphorus Point/Nonpoint Source 2003 

22900 104 Trib To Mud Fork (Rm 1.06) Sediment Nonpoint Source 2006 

22899 109 Hamilton Ditch Sediment Point/Nonpoint Source 2006 

10863 114 

Sandusky River Mainstem 

(Downstream Tymochtee 

Creek To Mouth) 

Habitat Alteration 

(TMDLs for total 

phosphorus and 

sediment) 

Nonpoint Source 2004 

33671 116 

Beaver Creek (Downstream 

Grand Lake St. Marys Dam To 

Mouth) 

Nitrate Nonpoint Source 2007

9446 119 Brush Run (Sugar Creek) Nitrogen Point/Nonpoint Source 2003

4172 123 Sandy Creek (L. Sandy Creek 

To Nimishillen Creek) pH Nonpoint Source 2003

22900 124 Sunday Creek (West Branch At 

Mouth) Acid Nonpoint Source 2006

10630 129 

Stillwater River (Upstream 

Swamp Creek To Upstream 

Greenville Creek) 

Phosphorus Point/Nonpoint Source 2004 

9582 130 Crosses Run Aldrin Nonpoint Source 2003 

3868 131 Little Miami River (North Fork 

To Massies Creek) Phosphorus Point/Nonpoint Source 2002 

10863 132 

Sandusky River (Headwaters 

To Upstream Broken Sword 

Creek) 

Sediment Nonpoint Source 2004 

9446 135 East Branch Sugar Creek Nitrogen Nonpoint Source 2003 

12274 136 W. Branch Alum Creek Phosphorus Point/Nonpoint Source 2005 

22900 140 Big Bailey Run Sediment Nonpoint Source 2006 

3.5.2 Nonpoint Source Implementation 

Nonpoint sources included in the Ohio TMDLs included agricultural runoff, bank erosion caused by 

livestock access and removal of vegetation, strip mining and deep mining, disposal of waste products, 

livestock grazing, abandoned mine areas, installation of subsurface tile systems, habitat modification, 

construction, and hydromodification. 

Thirty-eight Section 319 projects were found that potentially could have been related to implementation 

of the Ohio TMDLs. However, several of these were not initiated in response to the TMDL because they 

did not focus on the TMDL pollutant, were completed many years prior to TMDL approval, or the 
TMDL Implementation Rates in EPA Region 5 Project Report 

practices occurred in the watershed but not upstream of the segment included in this study. The project 

team used their best judgment to determine if the Section 319 projects represented TMDL 

implementation, but the information to make a conclusive decision was often not available. 

A number of other nonpoint source projects were also identified as a result of this study. These included 

agricultural practices implemented through USDA programs, EPA Targeted Watershed grants, and U.S. 

Fish and Wildlife Service grants. Some of the challenges associated with the Section 319 projects also 

applied to these projects such as difficulty determining whether practices were installed upstream of the 

TMDL segment and whether implementation occurred because of or coincident to the TMDL. As with the 

other states, projects that were completed within three years prior to TMDL approval were counted 

towards TMDL implementation if the practices matched the pollutant of concern and were upstream of 

the impaired segment. 

3.5.3 Information Sources 

A summary of all the Web sites that were accessed to obtain information on the Ohio TMDLs is provided 

in Table 3-14. The list of state and local contacts is provided in Table 3-15. The project team also 

obtained information about many of the TMDLs in this study from Dr. John Hoornbeek of Kent State 

University who had previously conducted a similar study tracking implementation efforts in Ohio and 

West Virginia. 

Table 3-14. Summary of online sources of implementation data. 

Agency Web Site Address Information Obtained 

Ohio EPA http://www.epa.state.oh.us/dsw/nps/319Program.html

Section 319 grant 

information and project 

summaries 

Ohio EPA http://www.epa.state.oh.us/dsw/permits/permit_list_district.html NPDES Permit Documents 

Ohio EPA http://www.epa.state.oh.us/dsw/tmdl/index.html Information on TMDL 

Documents 

County 

SWCDs http://www.dnr.state.oh.us/sw/default/tabid/8637/default.aspx Individual county 

information 

ODNR http://www.dnr.state.oh.us/H_Nav2/Water/WatershedCoordinatorProgr

am/tabid/9192/Default.aspx

Watershed coordinator 

information 

USEPA http://iaspub.epa.gov/pls/grts/f?p=110:1:4642271311943480::NO

Section 319 Grants 

Reporting and Tracking 

System (GRTS)- 319 

project information 

ODNRMRM http://www.watersheddata.com/

319 project summaries for 

Sunday Creek, Monday 

Creek and Upper Raccoon 

Creek 

23
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-15. List of state and local contacts. 

Agency Contact Person Information Obtained 

Cuyahoga River Community 

Planning Organization Charles Hambly NPS implementation activities occurring in Lower Cuyahoga 

Darke SWCD Greg McGlinch NPS implementation activities occurring in Darke county 

Delaware SWCD Kris Bruestle NPS implementation activities occurring in Delaware county 

Geauga SWCD Carmella Shale NPS implementation activities occurring in Geauga county 

Grand Lake/Wabash 

Watershed Alliance Laura Walker NPS implementation activities occurring in Grand Lake/Wabash watersheds 

Green SWCD Don Leeds NPS implementation activities occurring in Green county 

Kent State University John Hoornbeek NPS implementation activities occurring in the watershed 

under study 

Malcolm Pirnie Kristen Risch NPS implementation activities occurring in Green county 

Monday Creek Restoration 

Project Mike Steinmaus NPS implementation activities occurring in Monday Creek watershed 

ODNR Greg Nageotte NPS implementation activities occurring in Upper Cuyahoga 

ODNR Jim Mizik NPS implementation activities occurring in Nobel County 

Ohio State University Richard Moore NPS implementation activities occurring in Sugar Creek 

watershed 

Paulding SWCD Joni Franklin NPS implementation activities occurring in Paulding 

watershed 

Raccoon Creek Watershed Ben McCament NPS implementation activities occurring in Raccoon Creek 

watershed 

Sandusky River Watershed 

Coalition Cindy Brooks NPS implementation activities occurring in Sandusky River watershed 

Sunday Creek Watershed 

Group Kaabe Shaw NPS implementation activities occurring in Sunday Creek watershed 

Tinker Creek Watershed 

Partner Mike McNutt NPS implementation activities occurring in Lower Cuyahoga 

Tuscarawas SWCD Traci Haey NPS implementation activities occurring in Tuscarawas 

county 

Union SWCD Terry Travatt NPS implementation activities occurring in Union county 

Washington SWCD Mary Campbell NPS implementation activities occurring in Washington 

county 

3.6 WISCONSIN TMDL SUMMARY

Implementation efforts for a total of 18 Wisconsin TMDLs were assessed as part of this study (Table 3-

16). All of the Wisconsin waterbodies were impaired solely by nonpoint sources resulting in no point 

source WLAs in any of the Wisconsin TMDLs. Sixteen of the Wisconsin TMDLs are for sediment and 

two are for phosphorus. All of the 18 Wisconsin TMDLs were developed as part of a watershed-TMDL, 

and all but four have some form of an Implementation Plan completed. 

24
TMDL Implementation Rates in EPA Region 5 Project Report 

Table 3-16. Summary of Wisconsin TMDLs. 

TMDL Sample 

Number TMDL ID Waterbody Name Pollutant TMDL Type TMDL Fiscal Year 

Sample 003 4234 Perennial Stream B 

(Tm2) Sediment Nonpoint Source 2003

Sample 007 12237 Twin Grove Branch Sediment Nonpoint Source 2005

Sample 008 4234* Perennial Stream A 

(Spp1) Sediment Nonpoint Source 2003

Sample 029 4257 North Branch Spring 

Brook1 Sediment Nonpoint Source 2003

Sample 032 12237 Dodge Branch Sediment Nonpoint Source 2005

Sample 049 1932 Squaw Lake Phosphorus Nonpoint Source 2000

Sample 052 4214 Jug Creek Sediment Nonpoint Source 2003

Sample 056 12237 Spring Creek Sediment Nonpoint Source 2005

Sample 063 3929 Token Creek Sediment Nonpoint Source 2002

Sample 065 4226 Welch Coulee Creek Sediment Nonpoint Source 2003

Sample 066 4226 North Creek Sediment Nonpoint Source 2003

Sample 069 4257 Spring Creek Sediment Nonpoint Source 2003

Sample 073 32078 Stillwell Creek Sediment Nonpoint Source 2007

Sample 080 4234 Perennial Stream D (B4) Sediment Nonpoint Source 2003

Sample 092 3929 Token Creek Sediment Nonpoint Source 2002

Sample 105 12237 Jockey Hollow Creek Sediment Nonpoint Source 2005

Sample 110 9505 Cedar Lake Phosphorus Nonpoint Source 2003

Sample 115 22521 Cochrane Ditch (Rose 

Valley) Sediment Nonpoint Source 2006

1

Corinne Billings of the WDNR noted that the waterbody in Sample 029 was incorrectly named. The waterbody name 

was corrected to North Branch Spring Brook. 

3.6.1 Point Source Implementation 

All of the Wisconsin TMDLs are nonpoint source TMDLs; therefore all point source-related 

implementation status categories are marked with an “N/A”. Implementation tracking efforts were 

focused on nonpoint source projects. 

3.6.2 Nonpoint Source Implementation 

One Section 319 project was found in GRTS for the Wisconsin TMDLs—the Dodge Branch streambank 

restoration project. The lack of other Section 319 projects is believed to be due to WDNR’s preference for 

using Section 319 funding for TMDL development, staff, and monitoring instead of implementation 

efforts. The implementation projects themselves are more frequently funded through various other state 

programs (e.g., Priority Watersheds and Priority Lake Program) and are typically managed by local Land 

and Water Conservation Departments. Because of this, nearly all of the implementation efforts fall under 

the “other nonpoint source projects” category. 

Most of the nonpoint source projects were implemented through the Nonpoint Source Priority Watershed 

and Priority Lake Program Grant program, other Wisconsin DNR funding sources (non-Priority 

Watershed Grants), or the Wisconsin Department of Agriculture. Conservation Reserve Enhancement 

Program (CREP) and EQIP were also cited several times as sources of implementation funding. 

25
TMDL Implementation Rates in EPA Region 5 Project Report 

3.6.3 Sources of Implementation Information 

A summary of all the Web sites that were accessed to obtain information on the Wisconsin TMDLs is 

provided in Table 3-17. Corinne Billings of the WDNR provided most of the information on the status of 

implementation for the Wisconsin TMDLs. Because of her experience as WDNR’s TMDL 

implementation coordinator and her close contact with the local Land and Water Conservation 

Departments, Ms. Billings made contact with the individual counties to determine what, if any, 

implementation had been completed for each of the TMDLs. Several other WDNR data sources were also 

mined for implementation information including WDNR watershed management records, WDNR 

nonpoint source grant records, and WDNR lakes and rivers grant records. 

One of the Wisconsin TMDLs (Stillwell Creek- Sample 073) was developed by EPA because the 

impaired waterbody is located on a federal military base. John Noble, the fisheries biologist at Fort 

McCoy, was contacted, and he provided implementation information for Stillwell Creek. 

Table 3-17. Summary of online sources of implementation data. 

Agency Web Site Address Summary of Information 

Obtained 

WDNR http://www.dnr.state.wi.us/org/water/wm/wqs/303d/EAP.html Wisconsin Environmental 

Accountability Projects 

WDNR http://www.dnr.state.wi.us/Org/caer/cfa/ef/nps/pwatershed.html

Nonpoint Source Priority 

Watershed and Priority Lake 

Program Grant 

WDNR http://www.dnr.state.wi.us/org/water/wm/wqs/303d/Approved_TMDLs.html Wisconsin Approved TMDL 

Documents 

County 

LWCDs http://www.walce.org/county_sites.asp

LWCD programs, Land and 

Water Resource Management 

Plans, projects, education, and 

other implementation efforts 

EPA http://iaspub.epa.gov/pls/grts/f?p=110:1:4642271311943480::NO::: 

Section 319 Grants Reporting 

and Tracking System (GRTS)- 

319 project information 

26
TMDL Implementation Rates in EPA Region 5 Project Report 

4 RESULTS AND OBSERVATIONS 

This section of the report summarizes several observations related to the data used for this study and 

presents the study results. 

4.1 DATA UPDATES

The project team found the following errors in the NTTS data system during the research conducted in 

support of this project: 

• Fifty-two TMDLs were categorized as nonpoint source only TMDLs. Three of these TMDL 

segments were found to actually be point/nonpoint source TMDLs. 

• Seventy-eight TMDLs were categorized as point/nonpoint source TMDLs. After further 

investigation, 35 of these were updated to nonpoint source only because there were no point 

sources upstream of those segments and no WLAs included in the TMDLs. This error was 

caused during the NTTS data entry process, when multiple-TMDL documents that addressed 

nonpoint-only and point/nonpoint segments were coded only as point/nonpoint for all their 

TMDLs. 

• Eight TMDLs were categorized as point source only TMDLs. Three of these were updated to 

point/nonpoint source TMDLs because the TMDL included LAs. Four additional TMDLs were 

updated to nonpoint source TMDLs after investigations determined that no point sources 

discharge upstream of those segments. These four segments were Ohio TMDLs for metals, for 

which the original point source was considered strip mining and deep mining but they were not 

assigned any WLAs. 

• One Minnesota TMDL was incorrectly labeled as being approved in 2003 when it was actually 

approved in 2006. 

 

These errors affected the breakdown of the TMDL types originally anticipated by EPA as a result of the 

NTTS query. Most appear attributable to NTTS data entry errors. Although correction did change the 

total samples per subpopulation, the range of sample sizes across all subpopulations of interest changed 

minimally (from an initial range of 52 to 86 samples to a corrected range of 50 to 88 samples.) The 

following is a summary of the final “TMDL types” list entered into the Access database: 

 

• Nonpoint source only TMDLs = 88 

• Nonpoint source and point source TMDLs = 49 

• Point source only TMDLs = 1 (statistically considered part of the mixed PS/NPS subpopulation, 

above) 

• Pre-2004 TMDLs = 51 

• 2004 to 2007 TMDLs = 87 

 

4.2 PROJECT RESULTS SUMMARY

The study design focused on quantifying the following seven statements concerning the full sample or 

specific subpopulations of the sample. Results below are presented both as actual frequencies in the 

sample and population percent estimates after sample weighting. These two forms of results are not 

intended to be identical, as the former is the straight proportion of the raw sample alone, and the latter is 

the estimated percent for the whole regional population of TMDLs after adjustment through statistical 

27
TMDL Implementation Rates in EPA Region 5 Project Report 

weighting. Quantities in parentheses indicate the number of sample TMDLs for which the statement was 

true (numerator) and the total number of sample TMDLs in the population or subpopulation that the 

statement addresses (denominator). Estimated percentages were derived after taking into account 

appropriate sample weighting factors for each subpopulation: 

1. The estimated overall rate of partial to full TMDL implementation for all types and dates of 

TMDLs in Region 5 is 80.3 percent (104/138 samples). 

2. The estimated rate of partial to full TMDL implementation for mixed and point source 

TMDLs in Region 5 is 88.8 percent (46/50 samples). 

3. The estimated rate of partial to full TMDL implementation for TMDLs including only 

nonpoint sources is 72.7 percent (58/88 samples). 

4. The estimated rate of partial to full implementation for TMDLs in Region 5 approved in 

FY2003 or earlier is 76.6 percent (39/51 samples). 

5. The estimated rate of partial to full implementation for TMDLs in Region 5 approved 

between FY2004 and FY2007 is 81.0 percent (65/87 samples). 

6. The estimated proportion of TMDLs in Region 5 with an implementation plan is 79.6 

percent (117/138 samples). 

7. The estimated proportion of TMDLs in Region 5 that were developed through multi-TMDL 

or watershed-TMDL analysis is 95.7 percent (123/138 samples).

Although full implementation of every practice related to a given TMDL was uncommon (less than 3% of 

the total), over 3⁄4 of the sample TMDLs had been at least partially implemented. As statements 1 through 

5 all address implementation rates, they allow for some comparison among subpopulations (Figure 4.1). 

One apparent pattern is that older and newer TMDL subpopulations did not differ significantly in 

implementation rates (76.6% and 81.0% respectively). In contrast, a 16.1% difference was observed in 

the rates of implementing NPS-only TMDLs (72.7%) and mixed NPS-PS TMDLs (88.8%). 

Figure 4.1. Comparison among sample population and subpopulations of estimated percent of partially to fully 

implemented sample TMDLs. Note rates vary around approximately 3⁄4 partial to full implementation, and the 

difference of 16.1% between NPS-only and mixed TMDLs. 

100%

75

50

25

Part/Full Implementation No Implementation

In all sampled watersheds

In samples with PS/Mixed TMDLs 80.3%

In samples with NPS-only TMDLs

In samples with pre-FY04 TMDLs

In samples with FY04-FY07 TMDLs

Size of subpopulations above 

24.6%

[138]

[xx]

[50]

[88]

88.8%

81.0%

72.7% 76.6%

[51]

[87]

34.1%

25.3% 23.5%

8.0%

100%

75

50

25

Part/Full Implementation No Implementation

In all sampled watersheds

In samples with PS/Mixed TMDLs 80.3%

In samples with NPS-only TMDLs

In samples with pre-FY04 TMDLs

In samples with FY04-FY07 TMDLs

Size of subpopulations above 

24.6%

[138]

[xx]

[50]

[88]

88.8%

81.0%

72.7% 76.6%

[51]

[87]

34.1%

25.3% 23.5%

8.0%

28
TMDL Implementation Rates in EPA Region 5 Project Report 

Statement 6 addressed the rates at which TMDLs in the sample were found to have a finalized 

implementation plan. Again, the data allow for comparison among the sample and the four 

subpopulations (Figure 4.2). The estimated overall rate observed in the regional sample was that nearly 

80% of the Region’s TMDLs have a completed implementation plan. Among the subpopulations, older 

TMDLs with plans (98.6%) exceeded newer TMDLs with plans (76.5%). The NPS-only TMDLs with 

plans (91.5%) also exceeded the mixed TMDLs with plans (66.5%). 

Figure 4.2. Estimated percent of TMDLs in sampled subpopulations that have an implementation plan. Note 

that 22.1% more implementation plans existed for older than newer TMDL samples, and 25% more for NPSonly than for mixed TMDLs. 

100%

75

50

25

Implementation No Implementation 

Plan Plan

In all sampled watersheds

In samples with PS/Mixed TMDLs 79.6%

In samples with NPS-only TMDLs

In samples with pre-FY04 TMDLs

In samples with FY04-FY07 TMDLs

Size of subpopulations above

15.2%

[138]

[xx]

[50]

[88]

98.6%

91.5%

76.5%

66.5%

[51]

[87]

26%

20.7%

11.4%

7.8%

100%

75

50

25

Implementation No Implementation 

Plan Plan

In all sampled watersheds

In samples with PS/Mixed TMDLs 79.6%

In samples with NPS-only TMDLs

In samples with pre-FY04 TMDLs

In samples with FY04-FY07 TMDLs

Size of subpopulations above

15.2%

[138]

[xx]

[50]

[88]

98.6%

91.5%

76.5%

66.5%

[51]

[87]

26%

20.7%

11.4%

7.8%

Because of the growing popularity of developing large watershed TMDL studies that encompass up to 

hundreds of TMDLs per study in the Region 5 states, the study also analyzed the frequency of multiTMDL or ‘watershed TMDL’ efforts and the proportion of partially to fully implemented samples that 

came from multi-TMDLs. The results of the analysis to quantify statement 7 demonstrated that multiTMDL approaches are well established regionally and appear to be increasing in recent years. Among 

subpopulations, all far exceeded three-quarters from multi-TMDL efforts. NPS-only TMDL samples 

(97.7%) did exceed mixed (93.4%), but not within the margin of error. Newer TMDL samples (97.5%) 

significantly exceeded older ones (84.3%) by a margin of 13.2%. Specifically as shown in Figure 4.3, the 

high and increasing frequency of a multi-TMDL approach across all subpopulations existed also for that 

subset of the sample that had been at least partially implemented (104 of the 138 sample TMDLs). 

The project team also explored possible associations between the TMDL implementation rates observed 

and potential explanatory variables, based on land use/land cover patterns in the watersheds of each 

sample TMDL. Land cover data were derived from the 2001 National Land Cover Dataset (NLCD) and 

the watersheds for each sample TMDL were custom-delineated. Aggregation of land cover statistics by 

TMDL sample watershed enabled the calculation of land cover proportions of interest, and reaggregation 

29
TMDL Implementation Rates in EPA Region 5 Project Report 

Figure 4.3. Frequency of partially to fully implemented TMDL samples associated with watershed or multiTMDLs, as separate from those developed as single TMDLs on single water bodies or segments. Note the 

percentage rise in this characteristic from older to more recent TMDLs is 19.1%. Figures not weighted. 

100%

75

50

25

Watershed or Single TMDLs

multi-TMDLs

In all sampled watersheds

88.5% In samples with PS/Mixed TMDLs

In samples with NPS-only TMDLs

In samples with pre-FY04 TMDLs

In samples with FY04-FY07 TMDLs

Size of subpopulations above

11.5%

[104]

[xx]

[46]

[58]

95.4% 93.1%

84.8%

76.3%

[38]

[65]

23.7%

15.2%

6.9% 4.6%

100%

75

50

25

Watershed or Single TMDLs

multi-TMDLs

In all sampled watersheds

88.5% In samples with PS/Mixed TMDLs

In samples with NPS-only TMDLs

In samples with pre-FY04 TMDLs

In samples with FY04-FY07 TMDLs

Size of subpopulations above

11.5%

[104]

[xx]

[46]

[58]

95.4% 93.1%

84.8%

76.3%

[38]

[65]

23.7%

15.2%

6.9% 4.6%

of samples into strata characterized by the predominance of specific land cover patterns. This analysis 

was conducted to gain insight on whether implementation rates might vary with widely different land use 

settings, e.g., urban vs. agricultural vs. less-developed rural watersheds (Figure 4.4). Consequently, this 

analysis departed from the subpopulations (older, newer, NPS-only, and mixed TMDLs) that were 

addressed in the original design and identified experimentally aggregated new subpopulations. The 

results obtained vary in the size (n) of the land use-related sample subpopulations, and some results 

therefore are not within the same margin of error targeted for the primary results. Sample weighting 

factors were not calculated for this portion of the analysis, thus percentages represent actual proportion of 

sample TMDLs rather than estimated proportion of these subpopulations. 

Generally, all the subpopulations examined closely paralleled the overall region-wide implementation 

rate. The analysis examined several levels of agriculture-dominated (including cropland and pasture) and 

cropland-dominated watersheds and found no evidence that these land cover types were associated with 

implementation rates significantly different than those observed overall. Similarly, urban-dominated 

watersheds did not depart from the overall pattern in regional implementation rate. A lower-intensity 

agriculture category, and a ‘rural’ category where neither agriculture nor urban uses dominated, also 

displayed no significant differences in rates. 

This sampling study and analysis of TMDL implementation rates provided insights into implementation 

across a six-state region, representing a scale at which no quantitative information on implementation 

previously existed. The primary seven statements around which the study was designed were able to be 

addressed and quantified. The findings estimate rates, quantify some associated factors, and fail to reveal 

other associations we tested. It is also probable that the limited resources and thus sample size available 

also limited the study findings we could verify within the targeted margin of error. The most prominent 

finding of this study is the evidence that, once approved, most of this region’s TMDLs are at least 

30
TMDL Implementation Rates in EPA Region 5 Project Report 

Figure 4.4. Percent of TMDL samples partly/fully implemented, reaggregated by predominant land cover in 

watershed. Some subpopulation sample sizes are too small to meet the +/- 10% margin of error, and sample 

weighting was not calculated. Note implementation rates across these subpopulations are similar to the region 

overall, suggesting that these land cover patterns do not explain implementation rates observed in this sample. 

Part/Full Implementation

In all sampled watersheds

High agriculture (> 50% agr)

High cropland (>50% crop)

Moderate agriculture (25-49%)

Low agriculture (0-24%)

Rural (<5% urban, <10% agr)

Urban watersheds (>10% urban)

Size of subpopulations above

[138]

78.9% [76]

[54]

[xx]

100%

75

50

25

75.4%

71.4%

78.9%

77.7% 75.0%

[22]

[40]

[54]

72.7%

[44]

Part/Full Implementation

In all sampled watersheds

High agriculture (> 50% agr)

High cropland (>50% crop)

Moderate agriculture (25-49%)

Low agriculture (0-24%)

Rural (<5% urban, <10% agr)

Urban watersheds (>10% urban)

Size of subpopulations above

[138]

78.9% [76]

[54]

[xx]

100%

75

50

25

75.4%

71.4%

78.9%

77.7% 75.0%

[22]

[40]

[54]

72.7%

[44]

partially implemented. Moreover, a developed implementation plan very frequently follows the TMDL 

itself in the six Region 5 states. 

The findings do suggest some factors exist that may influence the rates that were observed but unable to 

be tested statistically. For example, the 16.1% difference between the NPS-only and the higher, mixed 

TMDLs rates may be due to the voluntary nature of NPS controls as compared to the enforceable, PSpermitting process affecting the implementation of the mixed TMDLs. The slightly increased 

implementation rate among newer vs. older TMDLs, despite the pre-2003 subpopulation’s longer time for 

implementation, may be related to possible improvements such as greater program capacity, funding, and 

commitment to action, or to developing more implementable TMDLs. The NPS-only TMDLs high 

percentage with implementation plans, in contrast to their somewhat lower implementation rates, may be 

strongly correlated with 319 watershed plans. On the other hand, the finding that mixed TMDL samples 

had fewer implementation plans but a greater frequency of partial implementation may be related to the 

high rate of permits mandatorily implemented whether or not a plan exists. The higher percentage of 

older TMDLs with completed plans than newer TMDLs may be explainable by the fact that TMDL 

development, implementation, and ultimate recovery is a many-year process that is in earlier stages 

among the newer sample TMDLs. Together these findings send a mixed message about the relationship 

of implementation plan completion and actual implementation. Overall, greater statistical power would 

have been particularly valuable to enable a more detailed examination and sub-categorization of the very 

broad ‘partially implemented’ category. 

The exploratory analysis of watershed land cover was intriguing in part because it did not reveal any 

statistically significant differences among the widely different land cover settings examined. The project 

team did not, however, consider this limited analysis conclusive that land cover does not contribute to 

31
TMDL Implementation Rates in EPA Region 5 Project Report 

explaining implementation rate differences in ways that were not tested. Based on NPS-only vs. mixed 

TMDL rate differences found, one might suspect that TMDLs in highly agricultural or rural watersheds 

would be significantly less implemented than urban TMDLs. The similar rates across these different 

watershed settings may in fact be linked to the existence of independent and very different drivers of 

implementation. Agricultural watersheds may have high rates due to the extensive reach of USDA 

funding for best management practices, whereas urban watersheds are likely much more influenced by 

stronger regulations and point source permitting situations. Exploratory analyses with more refined 

watershed land cover data, or using the data only within a corridor of much closer proximity to the 

impaired water, may generate different results. Also, socio-economic factors and other geo-spatial data 

may be explored as possible explanatory factors. 

4.3 OBSERVATIONS

This section of the report offers a variety of observations made by the project team in conducting this 

study, including analysis of the results and several aspects of the study design and available data. 

4.3.1 Study Results 

The estimated overall rate of partial to full TMDL implementation was higher than expected at the onset 

of the study. This is likely due to a combination of the following factors: 

• Very few of the TMDLs were found to be fully implemented. However, many TMDLs were 

found to be partially implemented. These included TMDLs where a significant number of 

practices have been installed as a result of the TMDL, but also TMDLs where there has been 

some but limited implementation. For example, several segments of the Wabash River in Indiana 

were included in this study with approved phosphorus TMDLs. The Wabash River drains more 

than 30,000 square miles and, although some practices were found to have been implemented for 

the segments of interest, the practices cover only a minimal portion of the area that eventually 

will need to be addressed to fully implement the TMDL. It is therefore unlikely that the high rate 

of partial implementation found in this study would presently be capable of producing a 

correspondingly high rate of water quality standards attainment. 

• Thirty-six percent of the TMDLs in the study included WLAs and, for the most part, these WLAs 

were found to have been implemented because the TMDL either confirmed existing permit limits 

or the new permit limits were found to be implemented (82 percent). The estimated rate of partial 

to full TMDL implementation for TMDLs including only nonpoint sources (approximately 66 

percent) was closer to what was initially expected when the study started. 

• It appeared that a variety of implementation efforts are indeed occurring within the TMDL 

watersheds that will address the pollutant of concern. These include efforts by agricultural 

landowners to adopt nutrient management plans, plant filter strips, and implement reduced tillage 

practices as well as efforts by communities and state and local government agencies to address 

failing septic systems, CSOs, abandoned mine drainage, and other problems. However, in some 

cases it was not clear if these efforts were a result of or coincident to the TMDL. The project team 

used whatever data were available and its best judgment to try and make this determination but it 

is certainly possible that some implementation has been attributed to the TMDL that actually 

would have occurred regardless. However, as TMDLs by nature usually identify a variety of 

implementation actions beyond those driven by the TMDL program or EPA resources, actions by 

other stakeholders that are not directly connected to but consistent with the TMDL can be 

expected. 

32
TMDL Implementation Rates in EPA Region 5 Project Report 

• The TMDL and Section 319 Programs in EPA Region 5 have placed an emphasis on 

implementation efforts for at least the past ten years, as have the states within the region. The 

unexpectedly high rate of implementation found in this study might, in part, reflect this emphasis 

and might not reflect typical implementation rates occurring in other regions or states. 

The high rate of TMDLs with Implementation Plans is consistent with Tetra Tech’s experience in Region 

5 and is attributed to the following factors: 

• Illinois EPA develops a majority of its TMDLs using contractor support and the development of a 

separate Implementation Plan is a required contract deliverable. 

• Minnesota’s Clean Water Legacy Act, through policy direction and funding incentives, has been 

a driving force behind the preparation of implementation plans for all Minnesota TMDLs. 

• Ohio EPA typically includes detailed descriptions of implementation activities in its TMDL 

documents. Many of these were considered to constitute Implementation Plans according to the 

definition provided in the project SOW. Furthermore, detailed Watershed Action Plans had been 

developed for four of the Ohio TMDLs. 

• Wisconsin implementation plans often come in the form of “Nonpoint Source Control Plans” that 

are developed for Priority Watershed Projects. Typically they are for larger watersheds and 

addressed the TMDL segments within this study. 

The high rate of partially to fully implemented TMDLs in Region 5 that were developed through multiTMDL or watershed-TMDL analysis is also consistent with Tetra Tech’s experience in Region 5. Illinois, 

Indiana, Michigan, Minnesota, and Ohio almost exclusively develop TMDLs on a watershed basis. 

4.3.2 Study Design 

Having to categorize TMDL implementation into one of only four categories (not implemented, partially 

implemented, fully implemented, or unknown) proved to be challenging. The majority of the TMDLs fell 

into the category of partially implemented but the range of partial implementation is considered to be 

fairly large. Similar future projects may want to consider additional subcategories of partial 

implementation, even though a re-analysis of the ‘partial’ category in this study showed that 

subcategories would be difficult to identify and document consistently. 

Including Minnesota’s State-wide mercury TMDL in this study also posed some challenges. First, the 

majority of mercury in water is related to atmospheric sources, both within and outside of Minnesota. 

Accordingly, emphasis in the TMDL and implementation plan is focused on mercury minimization 

programs. These efforts are outside the scope of traditional water-related implementation programs, such 

as Section 319. Second, because of the large number of segments included in the state-wide mercury 

TMDL, the sample set was unintentionally drawn away from capturing implementation occurring for 

more traditional TMDL settings. This was noted by the state TMDL Coordinator, particularly in light of 

the high level of support for TMDL implementation in Minnesota that has resulted from the state’s Clean 

Water Legacy Act (more than $70 million in funding from FY2006 – FY2009). 

To a lesser extent, the inclusion of eight segments from the Wabash River TMDL also posed some 

challenges to this study. The Wabash River watershed is very large (more than 30,000 square miles) and 

therefore the subwatersheds draining to each of the segments included in this study were also very large. 

This size meant that there were a large number of potential point source and nonpoint source projects that 

had to be evaluated. Tetra Tech was fortunate to have many of the geographic information system (GIS) 

files needed to conduct this analysis because of supporting the development of the TMDL, but the 

33
TMDL Implementation Rates in EPA Region 5 Project Report 

discrepancy in the size of the Wabash River segment watersheds compared to others in the study could 

potentially skew the results. 

4.3.3 Gaps in Appropriate Information 

An important observation made during the collection of data for this report was that in no state was all of 

the required information already compiled (let alone compiled in a central database or tracking system). 

Although a great deal of the background information on the TMDL, the permits, and the nonpoint source 

projects was available in central databases such as NTTS, PCS/ICIS, and GRTS, most of the detailed 

information regarding implementation status had to be retrieved through personal contact with state 

personnel or local stakeholders. This was true for the TMDLs where most of the implementation 

information had to be obtained by the project team, but also true for the TMDLs where state personnel 

took much of the lead in obtaining the information. 

Additionally, in reviewing nonpoint source implementation projects, one issue surfaced that warrants 

discussion relative to tracking progress. Implementation actions can involve targeted areas, targeted 

programs, targeted activities, and targeted participants. Targeted areas include actions on specific parcels 

of land or work involving construction of identifiable facilities. Examples include fencing, riparian 

buffers, manure waste handing facilities, or off-site watering. These actions can be connected with 

quantifiable measures that relate to points on a waterbody. On the other hand, targeted programs, targeted 

activities, and targeted participants, while clearly instrumental to achieving environmental results, pose 

some challenges in relating actions to traditional “on the ground” measures. 

With this in mind, many of the implementation actions identified for some of the TMDLs involve 

targeting broad programs, activities, and participants across the watershed. Work is clearly occurring. 

However, tracking specific locations is difficult. Examples include the Lower Otter Tail TMDL Sediment 

Reduction Section 319 project in Minnesota. The focus of this project is education work with land owners 

in the watershed to promote an array of erosion control projects designed to collectively reduce sediment 

loads to the Lower Otter Tail River. The project also includes efforts intended to lead to a county-wide 

erosion control ordinance, as well as work to retire erosion prone land from crop production. 

Similarly, Section 319 project efforts to implement the Long Prairie River TMDL in Minnesota and 

reduce oxygen demanding wastes involve education and technical assistance to local landowners. This is 

also the case with implementation of the southeast Minnesota bacteria TMDL. Implementation projects 

include education and technical assistance to small feedlot owners, homeowners served by on-site septic 

systems, and landowners targeted for improved pasture management practices. Minnesota’s CWLA is 

also funding wide-spread implementation efforts in each of the TMDL watersheds reviewed for this 

project. Again, many of the projects are education and technical assistance efforts aimed at targeted 

participants, targeted programs, and targeted activities. The philosophy is that pollutant sources are often 

spread across the watershed and that solutions will require efforts that go beyond site-specific approaches. 

Tracking the net result of these education activities was beyond the scope of this study; nevertheless, the 

focus of the analysis was on carrying out actions called for in the TMDLs, not measuring environmental 

changes subsequent to those actions. 

Determining whether a nonpoint source contributor had implemented actions consistent with a TMDL 

would have also been much more straightforward if such information was specifically recorded in GRTS 

or a project report. Since it wasn’t, the project team had to rely on trying to determine the specific 

location of the practice and then compare that location to the location of the impaired waterbody. A 

comparison also had to be made between the practice installed and the TMDL pollutant (e.g., a nutrient 

management plan was not considered implementation of an E. coli TMDL). 

34
TMDL Implementation Rates in EPA Region 5 Project Report 

Just knowing that a practice occurred in the watershed was insufficient to assess implementation of the 

specific TMDLs included within this study because almost all of the TMDLs were developed on a 

watershed basis and there were therefore other TMDL segments in the same watershed that were not a 

part of the study. GIS files for practices were only available in a few cases and even detailed descriptions 

of the practice locations were difficult to obtain. Information in GRTS typically lacked spatial detail and 

the Section 319 annual reports were often only marginally better (e.g., “section 319 grant funding is 

awarded to restore approximately 1,400 linear feet of an unnamed tributary to the Chagrin River”). The 

project team therefore had to try to contact local officials familiar with the grant (which was time 

consuming) or use best professional judgment to assess whether a known practice occurred upstream of 

the TMDL segment. In several cases, the team was unable to find anyone knowledgeable of the location 

of the referenced projects. For example, the Duck Creek (Ohio) watershed coordinator had changed 

positions and his replacement did not have the necessary information on the project location. 

4.4 Additional Analysis of Partially Implemented TMDLs 

The TMDLs determined to be partially implemented were further explored through additional analysis. 

EPA requested this additional analysis because the original study design requested categorization of 

TMDL implementation into one of only four categories: Not Implemented, Partially Implemented, Fully 

Implemented, or Unknown. The majority (100 out of 138) of the TMDLs fell into the Partially 

Implemented category, but the range of partial implementation was considered to be fairly large (i.e., 

some TMDLs could be minimally implemented and others extensively implemented). Although 

consistent subcategories of partial implementation would clearly be difficult to assign consistently due to 

substantial variation among TMDLs and their data limitations, any additional insights on degree of 

implementation were seen as highly desirable. 

A number of potential methods for assessing the degree of partial implementation were identified, 

including determining the proportion of the total number of practices identified in the TMDL 

implementation plan that have been implemented, determining whether any action has occurred yet for 

TMDLs that necessitated NPDES permit changes, estimating the load reduction achieved by the 

implemented practices, and “scoring” each TMDL found to be partially implemented based upon factors 

such as the number of 319 projects implemented, or the number of WLAs incorporated into permits. 

In general, there were challenges with implementing each of the approaches, mostly due to data 

limitations but also in some cases due to resource constraints. For example, although some TMDLs or 

implementation plans do include a “menu” of practices, information as to whether each practice has yet 

been implemented was usually lacking. Similarly, considerable effort was involved in going back to the 

original TMDL documents just to create the “checklist” of implementation practices because the 

information had not previously been organized in that way. 

Despite the challenges some significant findings were still obtained. Nine case studies were chosen for the 

implementation “menu” approach and, in eight of the nine TMDLs, at least 40 percent of the identified 

practices had been implemented. For the partially implemented TMDLs that included revised WLAs for 

WWTPs, 100 percent of the WLAs were found to have been established in new permit limits. 

Additionally, “scoring” of the partially implemented TMDLs resulted in 76 percent of the TMDLs 

receiving at least 3 points on a 6-point scale. 

35
TMDL Implementation Rates in EPA Region 5 Project Report 

Several TMDLs were also researched in greater detail to estimate the load reductions likely to be 

achieved by the documented implementation measures. Unfortunately, only 3 of the 100 partially 

implemented TMDLs had sufficient information on the extent and location of controls to be able to 

conduct such an analysis. For these 3 TMDLs, the already implemented controls were found to have 

controlled 4 percent, 52 percent, and 86 percent of the needed load reductions (see Appendix 2 for 

details). 

36
TMDL Implementation Rates in EPA Region 5 Project Report 

APPENDIX 1: 

DEFINITIONS OF KEY TERMS 

TMDL: A TMDL or Total Maximum Daily Load is a calculation of the maximum amount of a pollutant 

that a waterbody can receive and still meet water quality standards, and an allocation of that amount to the 

pollutant's sources. TMDLs are calculated as the total Waste Load Allocation (WLA, allocated to point 

sources) plus the total Load Allocation (LA, allocated to nonpoint sources) plus a margin of safety. For 

counting purposes, a single TMDL addresses one water body segment (state-defined) and one pollutant. 

One water body may have multiple pollutants and therefore multiple TMDLs. 

TMDL Document: A report submitted to an EPA Region by a state that provides the detailed 

calculations and plans for one or more final, approved or established TMDLs. One TMDL document does 

not equal one TMDL; rather one document may address many TMDLs, e.g., in the case of a large 

watershed plan affecting multiple impaired waters and/or multiple pollutants. 

Implementation: a sequence of actions including new or altered pollution control practices that are 

carried out to reduce pollutant loading consistent with the terms of a TMDL. Implementation actions can 

include onsite installation, operation, maintenance, and adjustment of nonpoint source control practices 

(Best Management Practices, BMPs) as well as issuance, reissuance or modification of PS control permits 

and practices. Implementation as used in this study does not encompass planning, funding, or completion 

of an implementation plan (i.e., implementation planning activities), nor changes in water body condition 

(i.e., post-implementation effects). 

Implementation Planning: post-TMDL activities that encompass planning or funding control practices 

and/or completion of an implementation plan. 

Post-Implementation Effects: changes in water body condition that are plausibly related to 

implementation actions taken. 

Partially Implemented: having any combination of actions listed under the implementation definition 

above that are verified as having occurred or currently active. 

Fully Implemented: available information indicates a TMDL that is fully implemented has had all point 

or nonpoint control actions completely put into practice onsite; note: in this meaning, full implementation 

of practices does not connote “fully implementing Water Quality Standards” and is completely 

independent from changes in condition caused by those practices. 

Not Implemented: available information indicates a TMDL that is not implemented has had none of the 

TMDL’s point or nonpoint control actions carried out fully or partially. 

Implementation Unknown: available information does not prove or disprove the implementation status 

of any of the control practices relative to a TMDL, all or in part. 

Implementation Plan: documentation of planned specific actions and schedules for those actions to be 

taken in order to reduce pollutant loading consistent with a TMDL; an implementation plan may take any 

of the following forms: 

• exists as stand-alone document 

37
TMDL Implementation Rates in EPA Region 5 Project Report 

• exists within TMDL document 

• exists as permit-related document(s) 

• exists as 319-related document or watershed plan 

38
TMDL Implementation Rates in EPA Region 5 Project Report 

APPENDIX 2: 

ADDITIONAL ANALYSIS OF PARTIALLY IMPLEMENTED 

TMDLS 

The TMDLs determined to be partially implemented were further explored through additional analysis. 

EPA requested this additional analysis because the original study design categorized TMDL 

implementation into one of only four categories: Not Implemented, Partially Implemented, Fully 

Implemented, or Unknown. The majority (100 out of 138) of the TMDLs fell into the Partially 

Implemented category, but the range of partial implementation was considered to be fairly large (i.e., 

some TMDLs could be minimally implemented and others extensively implemented). General 

characteristics of the partially implemented TMDLs are presented in Table A-1 and Table A-2. 

Table A-1. Overall Partial TMDLs Summary Table. 

Overall Partial TMDL Summary 

Total Number Impaired by Point Sources Only 1 

Total Number Impaired by Nonpoint Sources Only 57 

Total Number Impaired by both Point and Nonpoint Sources 42 

Total Number of "Partial" TMDLs 100 

Table A-2. Partial TMDLs by State. 

Number of Partial TMDLs by State 

Illinois Partial TMDLs 12 

Indiana Partial TMDLs 13 

Michigan Partial TMDLs 9 

Minnesota Partial TMDLs 27 

Ohio Partial TMDLs 24 

Wisconsin Partial TMDLs 15 

Total Number of "Partial" TMDLs 100 

A number of potential methods of assessing the degree of partial implementation were identified, 

including determining the proportion of the total number of practices identified in the TMDL 

implementation plan that have been implemented, determining whether any action has occurred yet for 

TMDLs that necessitated NPDES permit changes, estimating the load reduction achieved by the 

implemented practices, and “scoring” each TMDL found to be partially implemented based upon factors 

such as the number of 319 projects implemented, the number of WLAs incorporated into permits, etc. The 

results of each analysis method are presented in the following sections. 

DETERMINING THE PROPORTION OF PRACTICES IMPLEMENTED

One approach to evaluating the extent of partial implementation is to determine the proportion of the 

practices identified in the TMDL or the implementation plan that have been implemented. This approach 

involves listing the identified practices mentioned in the TMDL report or implementation plan and then 

confirming whether or not they have been implemented. Although this approach provides a general 

assessment of the extent of implementation activity, it should be noted that skewed results are possible 

39
TMDL Implementation Rates in EPA Region 5 Project Report 

due to the variable importance of the practices. For example, one practice might address 90 percent of the 

required load reduction whereas another nine practices only address the last 10 percent. 

Establishing the “menu” of the implementation practices for each TMDL was a fairly intensive effort as 

most of the reports did not have the information organized that way. In addition, comprehensive 

information as to whether each practice has or has not yet been implemented was usually lacking. 

Because of this, there were inadequate resources to apply this approach for all 100 partially implemented 

TMDLs. Instead, the nine partially implemented TMDLs for Michigan were used to test this approach. 

The results are shown in Table A-3 and indicate that in eight of the nine TMDLs, at least 40 percent of 

the identified practices had been implemented 

Table A-3. Determining the proportion of practices implemented in the nine partially 

implemented Michigan TMDLs. 

Number of Practices: 

TMDL 

ID 

Recommended in TMDL or IP Implemented  Unknown Not Implemented 

Percentage 

Known to 

Have Been 

Implemented 

Notes 

12239 8 1 7 0 13%

Detailed list of implementation practices available but 

information only exists to confirm that implementation is 

occurring, not as to which specific practices. 

3847 1 1 0 0 100% The one practice listed has been partially implemented. 

3838 1 1 0 0 100%

The implementation recommended in the TMDL was only a 

very general statement; contact confirmed some 

implementation has occurred, which could apply to one 

practice or a whole suite of practices; we do not have the 

detailed information. 

12277 1 1 0 0 100% The one practice listed has been partially implemented. 

3658 5 2 3 0 40% Easements and point source implementation known to have 

occurred; unclear if other mentioned practices have occurred. 

32213 1 1 0 0 100% The one practice listed has been partially implemented. 

4270 1 1 0 0 100% The one practice listed has been partially implemented. 

9499 7 3 3 1 43% Certain educational practices are known to have been 

implemented. 

3840 11 5 5 1 45%

A variety of practices related to one another have been 

implemented; status of some others unknown and status of 

one known to have not been implemented. 

DETERMINING ACTION ON NPDES PERMIT CHANGES

Another approach to determining the extent of partial implementation is to assess whether any action has 

occurred yet for TMDLs that necessitated NPDES permit changes. Tetra Tech had this information 

readily available from our initial efforts and therefore simply categorized each TMDL WLA into one of 

the following three categories: 

• Category 1: WLA in TMDL consistent with existing permit limits and therefore no permit 

revisions needed 

• Category 2: WLA requires permit revisions; permit revisions have been made 

40
TMDL Implementation Rates in EPA Region 5 Project Report 

• Category 3: WLA requires permit revisions; permit revisions not yet made 

There were a total of 399 WLAs included in the 100 partially implemented TMDLs and 272 of these fell 

into Category 1. Of the remaining 127 WLAs, 45 fell into Category 2 and 82 fell into Category 3. 

However, all of the 82 WLAs in Category 3 were for stormwater or combined sewer overflow sources for 

which permit revisions are not straightforward. For example, EPA is currently in the process of finalizing 

the TMDLs To Stormwater Permits Handbook which is intended to provide better information on how 

TMDL WLAs should be implemented in stormwater permits. All of the WLAs for more traditional point 

sources were found to have been implemented through permit changes. Most of these were for wastewater 

treatment plants in Ohio that received new nutrient permit limits as a result of the TMDLs. 

ESTIMATING THE PERFORMANCE OF CONTROLS 

Several TMDLs were researched in greater detail to estimate the load reductions likely to be achieved by 

the documented implementation measures. This was done to compare the expected load reductions to the 

levels identified as needed in the TMDL reports. Comprehensive information on the extent of 

implemented controls was found to be frequently lacking. As a result, only 3 of the 100 TMDLs had 

sufficient information on the extent and location of controls to easily be able to estimate their 

effectiveness. 

Homer Lake 

The Homer Lake phosphorus TMDL was developed by the Illinois EPA and approved by the U.S. EPA in 

2006. The nonpoint sources contributing to phosphorus loading in the Homer Lake watershed include 

sheet and rill erosion, agricultural and residential fertilizer, illicit wastewater connections, and internal 

phosphorus recycling. 

Implementation Efforts 

Though not all of the implementation has been a direct result of the TMDL, extensive efforts have been 

underway in the Homer Lake watershed before, during, and after TMDL development. Most of the 

implementation work in this watershed is due to a Section 319 project awarded in 2004 and completed in 

2007. This project led to the implementation of the following nonpoint source controls: 5 acres of 

grassed waterways, two ponds, 4,000 feet of field border strips, 3,000 acres of conservation cropping, 34 

acres of filter strips, 120 acres using deep phosphorus placement, and 4,950 acres using nutrient 

management planning to calculate appropriate fertilizer application rates. 

Anticipated Reductions 

Information included in the Homer Lake TMDL implementation plan (Illinois EPA, 2007) was used to 

estimate pre-implementation and post-implementation loads of phosphorus in the watershed. These 

estimates are summarized in Table A-4 and indicate that the implementation has achieved approximately 

52 percent of the needed reduction. In other words, the TMDL has been approximately half implemented. 

41
TMDL Implementation Rates in EPA Region 5 Project Report 

Table A-4. Estimated total phosphorus load reductions resulting from Homer Lake 

implementation efforts (based on data from the Homer Lake Implementation Plan [Illinois 

EPA, 2007]). 

Source of 

Phosphorus 

PreImplementation 

Load1

Load 

Reduction 

Needed1

Implemented BMP Reported 

Effectiveness

Estimated Load 

Reduction That 

Has Occurred 

34 acres of Filter Strips 65% 11 to 33 lbs/yr 

3,000 acres of 

conservation tillage 76% 1,140 to 3,420 lbs/yr 

5 acres of grassed 

waterways 30% 1 to 2 lbs/yr 

Row crop 

agriculture 

0.50 lb/ac/yr to 

1.6 lb/ac/yr on 

9,890 row crop 

acres = 

4,945 lb/yr to 

14,835 lb/yr 

3,462 lb/yr to 

10,385 lb/yr 

5,070 acres under 

nutrient management 

plans 

35% 887 to 2,662 lbs/yr

Failing septic 

systems 

580 lb/yr to 

2,310 lb/yr 

406 lb/yr to 

1,617 lb/yr No known implementation has occurred 

Internal 

Loading 40 lb/yr 28 lb/yr No known implementation has occurred 

Atmospheric 

deposition 15 lb/yr 11 lb/yr No known implementation has occurred 

Totals 5,580 lb/yr to 

17,200 lb/yr 

3,906 lb/yr to 

12,040 lb/yr 

2,039 lb/yr to 

6,117 lbs/yr 1

The TMDL does not present the existing loads by individual source category. The individual source loads are 

presented in the Implementation Plan and were combined with the TMDL’s recommendation for a 70 percent 

reduction to create this table. 

Argyle Lake

The Argyle Lake phosphorus TMDL was developed by the Illinois EPA and approved by the U.S. EPA in 

2007. The nonpoint sources contributing to phosphorus loading in the Argyle Lake watershed are listed as 

agriculture, recreation, and forest. 

Implementation Efforts 

One Section 319 project has been completed in this watershed. A grade stabilization project was 

completed in a gully draining to Argyle Lake. This implementation project was primarily focused on 

stabilizing erosion in a gully and aimed to reduce sediment delivery to the lake. However, phosphorus is 

typically associated with sediment runoff and this project was therefore anticipated to result in both 

sediment and phosphorus load reductions. 

Anticipated Reductions 

Illinois EPA estimated that 153 lbs/yr of phosphorus would be reduced from stabilizing the gully draining 

to Argyle Lake. Little is known about this project so it is difficult to determine whether this is a 

reasonable estimate. The TMDL identified that 178 lbs/yr of phosphorus needed to be reduced and 

therefore this TMDL appears to be 86 percent implemented. 

Otter Tail River – Breckenridge Lake to Bois de Sioux River 

The Otter Tail River sediment TMDL was developed by the Minnesota Pollution Control Agency and 

approved by the U.S. EPA in 2007. Nonpoint sources of sediment loading to the Otter Tail River include 

stormwater runoff, illicit connections, and agricultural inputs. 

42
TMDL Implementation Rates in EPA Region 5 Project Report 

Implementation Efforts 

One Section 319 project has been partially implemented in this segment. The objective of this project was 

to reduce sedimentation in the Otter Tail River through education and cultural/structural BMPs. Four 

sediment sources are targeted including wind erosion, water erosion, streambank erosion, and in-stream 

erosion. 

Another implementation project for the Otter Tail River has been funded with Minnesota Clean Water 

Legacy Funds. Clean Water Legacy Act funds are being used in conjunction with existing state and 

federal conservation programs to install conservation practices that reduce erosion, sediment, and 

turbidity. Targeted activities include conservation tillage, windbreaks, buffer strips, bio-fiber rolls, jetties, 

and stream barbs. 

Both projects fall within the Otter Tail River watershed and are specific to this TMDL segment. BMP 

areas are not provided in the details of either project. 

Anticipated Reductions 

The Wilkin County Local Water Management Plan (Wilkin County, 2008) estimates the Clean Water 

Legacy Act projects will result in a load reduction of 2,645 tons of sediment per year. It is unclear how 

these anticipated reductions were calculated. 

The Otter Tail River TMDL is summarized in Table A-5. The TMDL separates the allocations into five 

flow categories (low, dry, mid-range, moist, and high). Allowable loads for each flow zone were 

estimated using a load duration approach, and the existing loads were estimated using the S-LOADEST 

model. Load reductions are only needed during moist and high flow conditions. Based on the existing 

loads and TMDL for the moist and high flow zones, the total load to be reduced is 63,254 tons/year. This 

TMDL appears to therefore be approximately 4 percent implemented (2,634 tons/year divided by 63,254 

tons/year). 

Insufficient information is available to estimate the load reductions occurring as a result of the Section 

319 projects. 

Table A-5. Otter Tail River TMDL Summary. 

Flow Zone Existing Load 

(tons/year) 

TMDL 

(tons/year) 

Stormwater 

WLA 

(tons/year) 

MOS 

(tons/year) 

LA 

(tons/year) 

Low Flows No Reductions 

Needed 20,477 365 6,205 13,870 

Dry Conditions No Reductions 

Needed 26,134 365 4,380 21,535 

Mid-Range 

Flows 

No Reductions 

Needed 33,069 365 2,555 30,295 

Moist Conditions 56,940 41,647 730 5,475 35,405 

High Flows 100,740 52,779 730 5,110 47,085 

“SCORING” OF PARTIALLY IMPLEMENTED TMDLS

Based on the results of surveying the 138 TMDLs included in this study, Tetra Tech has determined that 

comprehensive information on the extent of implemented controls is frequently lacking. Although 

information about the general nature of implementation is usually available (e.g., fencing was installed) 

43
TMDL Implementation Rates in EPA Region 5 Project Report 

44

the specifics are usually not (e.g., 1500 linear feet of fencing were installed between river mile 3 and 4 of 

Duck Creek). The lack of such information makes it difficult or impossible to quantitatively estimate the 

likely effectiveness of the controls as was done for the three TMDLs described previously. Instead, only 

qualitative evaluations can be performed. 

To test one qualitative approach we developed a methodology to apply to the partially implemented 

TMDLs included in this study (only the 79 non-mercury TMDLs were included). To try and ensure 

consistency in the qualitative evaluations, a “scoring system” was developed. Each TMDL found to be 

partially implemented was “scored” based upon the criteria listed in Table A-6. The scoring approach 

varied depending on whether the TMDL included only nonpoint sources or both point and nonpoint 

sources1. Points were variably assigned to each type of TMDL to ensure the same maximum potential 

score for each type. Each TMDL was scored based upon the information already existing in the study 

database; no additional contacts were made to obtain new information for the scoring. 

Table A-6. Number of points assigned to evaluate degree of partial implementation. 

Criteria NPS 

TMDLs 

PS 

Only 

and 

NPS/PS 

TMDLs 

Is there an active Section 319 project? 1.5 1 

Is there an active Section 319 project that is directly tied to the TMDL? 1.5 1 

Is there an active non-Section 319 project addressing nonpoint sources? 1.5 1 

Is there an active non-Section 319 project addressing nonpoint sources that is directly tied to the TMDL? 1.5 1 

Have some of the WLAs been incorporated into permit revisions? NA 1 

Have all of the WLAs been incorporated into permit revisions? NA 1 

Maximum Score 6 6 

The results of the scoring are summarized in Table A-7 and indicate that 24.1 percent of the TMDLs had 

relatively little implementation (2 points or less), 54.5 percent had a moderate level of implementation (3 

or 4 points), and 21.6 percent had an extensive level of implementation. Thus, it appears that the general 

finding of the original study holds true – a large subset of the total population does indeed appear to have 

experienced a meaningful level of implementation. Only a relatively small number of the TMDLs appear 

to have been categorized as partially implemented due to having some, but not much, implementation. 

 

1 Only one of the 100 partial TMDLs was listed as only having point source impairments – the bacteria TMDL for 

the Saline River in Michigan (Sample #17). There are three point sources upstream of this TMDL segment, all of 

which are wastewater treatment facilities. The WLAs have been incorporated into NPDES permits for each of the 

three facilities and all are meeting the permitted limits. However, other sources of bacteria include illicit sewer 

connections and stormwater inputs. Because these sources have not yet been addressed, this TMDL was categorized 

as being partially implemented. 
TMDL Implementation Rates in EPA Region 5 Project Report 

45

Table A-7. Summary of partial TMDLs by score. 

Points # of TMDLs Percent Cumulative Percent 

1 2 2.5% 2.5% 

1.5 13 16.5% 19.0% 

2 4 5.1% 24.1% 

3 33 41.8% 65.8% 

4 10 12.7% 78.5% 

4.5 4 5.1% 83.5% 

5 4 5.1% 88.6% 

6 9 11.4% 100.0%