What are the limitations with the Proactive Approach?
Because almost all state resources at this time are focussed on TMDL development, the biggest limitation is likely the lack of funding. This is because Virginia is required to submit a certain number of TMDLs every biennium and currently has no additional funds to support the proactive approach. However, numerous other funding sources are available that may be applied to this approach. The second limitation is organizational – in order for the approach to work, a watershed group or locality has to commit time and resources to focus and keep track of the restoration activities. On the other hand, this limitation also provides for the flexibility at the local level to address water quality problems in a targeted way. The third limitation is timing. All waters listed on Virginia’s 1998 303(d) list of impaired waters need to be meeting water quality standards or have a TMDL by 2010. With the “2-year look back requirement”, this does not allow much time for restoration activities.
