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The Spokane River does not have enough dissolved oxygen (DO) during the months of April through October to meet current Water Quality Standards. The best available science shows that excess phosphorus is the main cause of this problem. There is agreement among those who petitioned Ecology in 2004, other interested parties and Ecology that actions are needed as soon as possible to improve the River’s condition, and, by assuring treatment capacity for septic tank discharges, further protect the quality of the Spokane Valley – Rathdrum Prairie Aquifer. Low dissolved oxygen also results from carbonaceous biochemical oxygen demand (CBOD) and ammonia. For the purpose of implementing the Spokane River Dissolved Oxygen TMDL, it is assumed that efforts to control phosphorus will also serve to control CBOD and ammonia. Reducing significant amounts of phosphorus in the River during the April-October season and achieving Water Quality Standards for dissolved oxygen are the goals of the Spokane River Dissolved Oxygen TMDL Managed Implementation Plan (MIP). In the October 2004 Draft Total Maximum Daily Load to Restore and Maintain Dissolved Oxygen in the Spokane River and Lake Spokane (Long Lake), Ecology estimated a reduction target of approximately 208 pounds/day of phosphorus from point sources, non-point sources and other controllable sources. Most of this reduction is anticipated to come from improvements in point source wastewater treatment technology located between the Idaho state line and the Lake Spokane Dam. The best available science conclusively demonstrates significant phosphorus reductions will improve DO in the River and Lake Spokane. How the River will respond to significant phosphorus reductions, the full extent of the reductions necessary to alleviate DO deficiencies, and the phosphorus reductions possible over the next 20 years are not precisely clear at this time. Hence, an aggressive, managed approach that removes phosphorus from a variety of sources through a variety of methods and monitors and assesses the impacts on DO over the next 20 years is a reasonable way to ma