The City's Wastewater Management Department is in the water cleanup and environmental protection business. Ecology sets the standards and we treat sewage in accordance with our permit. The City is also charged with prudent use of ratepayers' and taxpayers' dollars. Any major project is studied up front to make certain we are spending those dollars wisely and achieving the intended objectives.

Following EPA's lead, Ecology is migrating from Class-based to Use-based standards, and Use-based standards must be developed or confirmed for each water body. The designated uses of the river should form the fundamental basis for the TMDL. The Spokane River Use Attainability Analysis (UAA) will determine – scientifically or economically – what standards should be established downstream of the State Line Bridge to Long Lake Dam. (See http://spokaneriveruses.net). Ecology does not have sufficient funding to perform the necessary Spokane River UAA in a timely fashion, so river dischargers have stepped up to conduct the UAA for Ecology's consideration. As each use for the river is analyzed, the standards necessary to protect that use may increase or decrease. Uses that do not exist and cannot be attained would not require standards.

The Spokane River UAA sponsors delivered its full analysis to Ecology in December 2004. It found that salmonid spawning and rearing do not and cannot occur in the lowermost depths of Long Lake Reservoir, which suggests that Ecology's proposed 8 milligrams per liter of dissolved oxygen is not needed year-round in every part of the river system. Unfortunately, Ecology did not accept the UAA for consideration, which led to the establishment of a process described above as the Spokane River TMDL Collaboration.

Beyond a TMDL for dissolved oxygen, there are several other TMDLs awaiting Ecology attention. The City is particularly concerned about the risks of developing TMDLs in series, including new standards for temperature, PCBs or metals. Such future TMDLs may conflict with previous ones. This is an issue the City will continue to raise with Ecology. We hope to establish effective standards, based on sound science, to achieve measurable water quality improvements.