Baseline year

Since the stormwater program advocates an accounting process for achieving the WLA, with a percent reduction in loading being the target, it is important to define the baseline condition from which calculations will be made. The baseline must include a year but may include additional information, such as a summary of BMPs considered in deriving the WLA. Baseline year is the year from which stormwater practices can be credited toward meeting a total maximum daily load (TMDL) wasteload allocation (WLA). That is, any best management practice (BMPs) or activity implemented during or after the baseline year that results in a reduction in pollutant loads from a municipal separate storm sewer system (MS4) to the impaired waterbody can be considered as progress towards meeting the MS4 wasteload allocation (WLA).

Most TMDL reports, TMDL Implementation Plans, or Watershed Restoration and Protection Strategy (WRAPs) reports now provide a baseline year. Many earlier TMDL reports did not provide this information. For TMDLs developed with short-term monitoring data, such as two or three years, the baseline year will be one of those years. When long-term monitoring data is used it is difficult to determine the appropriate baseline year. TMDL authors, TMDL project managers, Stormwater Program staff, and stakeholders work together to determine an appropriate baseline year.

Examples of baselines from TMDLs developed in Minnesota are provided below. In general, more recently-approved TMDLs provide clearer target loads and baselines.

• Minnesota River Dissolved Oxygen TMDL – The report states that no BMPs were considered in the modeling. The model scenario chosen for setting the allocations was based on 1988 data. The baseline is therefore a no-BMP situation in 1988.
• Long-Farquar Lakes – Individual WLAs are provided for each MS4 on a lbs/day basis. The TMDL does not define a specific year. The TMDL was based on data for three years – 2001, 2003, and 2005. The baseline is therefore either a WLA on a lb/day basis or a percent or mass reduction from 2003, which represents an intermediate year.
• Kohlmann Lake TMDL – The WLA is expressed as lbs/day and as a percent reduction. The TMDL states that 2001 provides a reasonable starting point for tracking reductions.

While BMPs implemented prior to the baseline year generally cannot be applied toward meeting the WLA, there may be exceptions, including but not limited to the following:

• the TMDL model does not account for BMPs implemented prior to the baseline year;
• the TMDL report, implementation plan, or WRAPs specifies certain BMPs or conditions under which BMPs implemented prior to the baseline year can be credited; or
• the permittee can demonstrate that specific actions or BMPs implemented prior to the baseline year were not reflected in the monitoring data used to set the TMDL.

The List of Approved TMDLs with MS4 WLAs includes the baseline year identified in the TMDL, or the MPCA recommended baseline year. Please click here to download the baseline year guidance document: File:TMDLbaselinesMS4.xlsx