The Water Environment Federation (WEF; Alexandria, Va.) submitted comments on a U.S. Environmental Protection Agency (EPA) memorandum, which calls for changes in some policies related to stormwater-based total maximum daily loads (TMDLs). In summary, WEF believes that this memo should be withdrawn and included with the stormwater rulemaking effort. This would allow for more input from the public and industry. It also would give EPA a chance to develop stronger guidance on complex issues, such as the use of surrogates as a measure of water quality as well as numeric limits. WEF has offered to provide EPA with case studies to better develop and clearly outline a stormwater-based TMDL strategy.