Challenges in Attaining Recreational Stream Standards for Bacteria: Setting Realistic Expectations for Management Policies and BMPs

Attainment of U.S. Environmental Protection Agency (EPA) recreational water quality criteria and state water quality standards for bacteria presents significant challenges to water resource managers in communities throughout the U.S. From a regulatory perspective, many communities are faced with Total Maximum Daily Loads (TMDLs) for bacteria, typically for either E. coli or fecal coliform. For local governments responsible for National Pollutant Discharge Elimination System (NPDES) Municipal Separate Stormwater (MS4) permits, this issue can be particularly challenging and many questions arise with regard to whether stormwater best management practices (BMPs) can reduce bacteria in stormwater runoff. Many valid questions exist regarding how attainable current stream standards are and what measures are truly meaningful in reducing bacteria in streams and in development of meaningful TMDLs. This paper provides a synopsis of Best Management Practice (BMP) performance data provided for bacteria in the International Stormwater BMP Database and discusses implications of these findings for stormwater managers. Findings from analysis of these data are used to provide some recommendations regarding the types of efforts that are expected to provide meaningful results in terms of water quality management policy and bacteria reduction in stormwater and receiving waters. Implications for development of TMDLs with the potential to provide real improvement of water quality is also discussed.