Public Participation in TMDL Development: Can There Be Too Much?

In the debate over the development of the Total Maximum Daily Load (TMDL) program, one of the few unquestioned principles has been that more public involvement in TMDL development is better. But is more public participation in TMDL development always better? This article reviews four different public involvement models in current use by State and EPA TMDL programs and evaluates the advantages and disadvantages of providing more or less intensive opportunities for public involvement. Provision of more public participation opportunities in TMDL development often results in TMDL decisions that have a higher degree of public support and are more likely to be implemented effectively. However, time and resource constraints often limit the ability to provide for more intensive public involvement in development of TMDLs. Moreover, an intensive public involvement approach sometimes makes it more difficult for interested stakeholders to participate effectively in the TMDL process, resulting in decisions that may not fully account for the existing range of public interests in TMDL decisions. This article offers recommendations for ensuring productive and equitable public participation in TMDL development.