TMDL — It Means Total Maximum Daily Load. Literally.

Because the District's TMDLs did not conform to the plain meaning of the words "Maximum" or "Daily." The decision is lengthy and complicated, because the statutory framework is complicated. What it boils down to is this: TMDLs are not directly utilized in setting permit limits and longer term maxima might be better suited to guiding permit decisions. Nonetheless, the statute requires that states and the District of Columbia must establish total maximum daily loads.

Here's the Judge's nice Article III take on the issue: