Uh, it's in the first chapter of the book I published eleven years ago. In that same book, I also warned about regulation of seasonal Class 3 Riparian Areas when the NRCD instituted lawsuits in all 50 states to establish TMDL regulations for non-point "pollution" sources. At the time it was for nitrate, but I wrote that it would soon be about silt.
Wherever there is dirt and water, there is mud. Whenever you mix mud and water, you get suspended silt. Mud is a nonpoint source of silt. Silt is found everywhere there is dirt, which is everywhere. If you want to control the use of dirt, just call it a pollutant! It isnt clean water any more, its dirty. People dont want dirty water. They want clean water. Just ask them.
To determine culpability for a source of silt is even harder than for nitrate. Nonpoint mud is a much harder sell for an initial action in nonpoint pollution enforcement than human feces. Natural causes of silt in the County of Santa Cruz vastly outweigh human contributions. Sources of silt vary by location and degree every year. To assign individual causes is highly subjective
The State Water Resources Control Board employs five specialists assigned to institute nonpoint TMDL standards in the Central Coast Region. At the time of this writing, one third of the TMDL documents on their web site deal with the San Lorenzo River Watershed. Why are they focusing upon such a small community as the San Lorenzo Valley, in a County with timber practices touted as some of the finest in the world?
Santa Cruz County is a perfect test environment for enforcement of TMDL upon sources of nonpoint silt. It is one of the few places in the world with both nonpoint nitrate problems from urban and agricultural sources and silt problems involving a rural/suburban forest, coho salmon, and timber harvesting. It also has an entrenched activist bureaucracy, a thoroughly proven political machine, and a university activist community with which to supply the experts to make it all happen.
Few, even on this forum, paid any attention. 'Oh, that's just a local issue in loony Santa Cruz.' Yeah, right.