Skip to Search
Skip to Navigation
Skip to Content

Step 5 - The 9 Elements, Annotated


Summary of the nine minimum elements to be included in Section 319-funded watershed plans for threatened or impaired waters.

In black are the infamous “9 elements” required for a Clean Water Act funded watershed plan, from A Quick Guide to Developing Watershed Plans to Restore and Protect Our Waters. US EPA 2013 (31pp!!). Our annotations follow each element in blue.

  1. Identify causes and sources of pollution
    This really isn’t your job. You should be able to pull this information from the actual TMDL document itself, which reviews this information as part of the TMDL approval process. If you have an IC-TMDL, this section is likely to say that your watershed is suffering from unspecified urban sources. (Thus the need for a surrogate).


  2. Estimate pollutant loading into the watershed and the expected load reductions
    See comments for “a”: again, you should be able to get this from the TMDL document itself. “Loading” refers to the amount of pollutant, in this case the surrogate pollutant of impervious cover. So, existing pollutant loading would be your estimate of current percent IC, and the expected load reductions would be the acres of IC disconnection/removal needed to reach the TMDL target.


  3. Describe management measures that will achieve load reductions and targeted critical areas
    This is where your list of priority projects (Step 4) will come in. For each one, you should have an estimate of the area of IC that will be removed or disconnected. The total disconnection should add up to an amount that will result in the TMDL target listed above in “b.”


  4. Estimate amounts of technical and financial assistance and the relevant authorities needed to implement the plan
    This obviously isn’t an exact science, but it would be a good place to talk about whether your town has the needed expertise in-house, or would need consulting help to evaluate proposed projects. If your priority projects analysis includes cost estimates, so much the better. And “relevant authorities” would mostly entail your town’s land use regulatory authority. This might be a good place to address the issue of IC disconnection on private property (for example, large commercial parking lots), and how that might be achieved. If you have a Stormwater Utility, this would be a good place to mention how it factors in.
  5. Develop an information/education component
    There are several good sources of information will help you to put together a modest campaign. See Step 8.


  6. Develop a project schedule
    Back to your list of priority projects. However, we recommend that you also make a strong case for opportunistic implementation.


  7. Describe the interim, measurable milestones
    This should include management-related milestones (changing regulations, forming committees, hiring consultants, etc.) as well as any targeted projects that you want to identify.


  8. Identify indicators to measure progress
    For the most part this will be acres of IC removed or disconnected. Other indicators of progress are also appropriate but may be beyond your scope. See Step 7.


  9. Develop a monitoring component
    Again, in this case “monitoring” can be translated as keeping track of IC. (Water quality and quantity monitoring would be great, but in many cases you many have to rely on other entities to do this). See Step 7 for an example spreadsheet that can help you keep track of your IC.