Los Angeles River and Ballona Creek Stakeholder-Led Total Maximum Daily Load (TMDL) A Comprehensive Collaboration for Water Quality Improvements and Beyond

In response to the 1999 Consent Decree resulting from Heal the Bay, et al. vs. United States Environmental Protection Agency (USEPA), Total Maximum Daily Loads (TMDLs) for water bodies in the greater Los Angeles (LA) basin were required to be developed on an aggressive schedule. The first one, the Trash TMDL, was developed in the absence of a collaborative stakeholder involvement effort and was met with stiff resistance from the regulated community. An ensuing lawsuit resulted in the TMDL being remanded back to the California Regional Water Quality Control Board (Water Board). To avoid similar litigation and conflict on future TMDLs, the USEPA and the Water Board prepared a TMDL strategy document inviting agencies and organizations to take on the role of a lead stakeholder, facilitating involvement and collaboration among community interests with the objective of developing TMDLs that would be cooperatively implemented by the regulated community. The City of LA accepted the invitation and is now leading the stakeholder-led TMDL effort for the LA River and Ballona Creek. This effort is called “CREST,” which stands for Cleaner Rivers through Effective Stakeholder TMDLs.Since the initiation of CREST in 2004, the stakeholder group has collaborated on the development of three TMDLs: Ballona Creek Toxics, Ballona Creek Bacteria, and LA River Bacteria. For the Ballona Creek Toxics TMDL, CREST developed joint comments among the stakeholders emphasizing compliance and implementation schedule issues. As a result, the draft TMDL was significantly revised to reflect stakeholder concerns while still achieving the Water Board's desired adoption time frame. For the Ballona Creek Bacteria TMDL, CREST prepared a TMDL Implementation Strategy document that focused on implementation options and monitoring strategies, including estimated costs and schedule. The document identified specific approaches and facilities for implementation emphasizing decentralized, watershed-based solutions versus large, end-of-pipe structural solutions. CREST is now in the midst of developing the LA River Bacteria TMDL with a time line of having the TMDL ready for adoption in 2007.