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Urban municipalities and agricultural interests have historically been at odds over the causes and cures for water quality problems. Interestingly, the TMDL program's emphasis on watershedbased assessment is forcing both parties towards a realization that they have common interests. The TMDL process is designed to identify impaired waters, control the sources of impairment, and bring waters into compliance with standards; however, both urban and rural interests are discovering that under wet weather conditions, the analysis is much more difficult and complex. The performance of wet weather controls and standards are often practically unattainable.

This paper examines some of the challenges of the TMDL program and how an adaptive management approach can help address them in a way that spreads the responsibility over point and nonpoint sources equitably and cost-effectively. It will explore how controls need to be implemented in a progressive, staged manner coupled with monitoring, reassessment, and review or revision of water quality standards.