A Guide to the Adaptive

Management Option for

Phosphorus in Wisconsin
Clean Wisconsin 2013
Table of Contents
Introduction ............................................................................................................................................................................... 6
Acknowledgements............................................................................................................................................................ 6
Chapter 1: Overview of the Phosphorus Rule and the Adaptive Management Option ............................... 8
1-1: Background .................................................................................................................................................................. 8
1-2: How the AMO Works................................................................................................................................................ 9
1-3: AMO vs. Facility Upgrades ................................................................................................................................... 10
1-4: Why the AMO Works .............................................................................................................................................. 10
1-5: How to Use This Handbook ................................................................................................................................. 11
Audience .......................................................................................................................................................................... 11
Additional Resources ................................................................................................................................................. 11
Chapter 2: Watersheds and Phosphorus in Wisconsin .......................................................................................... 13
2-1: Overview of Watersheds ...................................................................................................................................... 13
2-2: Water Quality Standards and Regulations .................................................................................................... 14
Types of Water Quality Standards ........................................................................................................................ 14
Discharge Permits........................................................................................................................................................ 15
2-3: Phosphorus Management and Regulation in Wisconsin ......................................................................... 16
Wisconsin’s Phosphorus Rule ................................................................................................................................. 16
Wisconsin Phosphorus Index.................................................................................................................................. 17
Chapter 3: Process and Timelines for the AMO ........................................................................................................ 19
3-1: Regulatory Timelines ............................................................................................................................................. 19
Compliance Schedules ............................................................................................................................................... 19
Steps for Developing and Submitting an AMO Plan ....................................................................................... 20
3-2: Planning Timelines ................................................................................................................................................. 21
Chapter 4: Determine Eligibility for the AMO............................................................................................................ 23
4-1: Eligibility Criteria for the AMO .......................................................................................................................... 23
4-2: Establish a Baseline Phosphorus Exceedance ............................................................................................. 24
Surface Water Data Viewer (SWDV) .................................................................................................................... 25
4-3: Determine the Proportion of Nonpoint Phosphorus Pollution in Receiving Water .................... 26
4-4: Obtain Your Facility’s Phosphorus WQBEL .................................................................................................. 26
4-5: Describe Your Facility’s Operation................................................................................................................... 27
4-6: Evaluate Your Watershed for the AMO .......................................................................................................... 28
Chapter 5: Phase 1 - Gather Data and Build Partnerships .................................................................................... 29
5-1: Determine What Information You Need ........................................................................................................ 29
Information Required for the AMO ...................................................................................................................... 29
Before You Begin .......................................................................................................................................................... 30
 5-2: Assess Your Watershed and Determine the Action Area ........................................................................ 30
What is my Watershed?............................................................................................................................................. 30
5-3: Build Partnerships with Stakeholders ............................................................................................................ 38
Identify a Facilitator ................................................................................................................................................... 38
Determine Farmer Leaders...................................................................................................................................... 39
Inventory Stakeholder Skills ................................................................................................................................... 39
Tips for Building Partnerships ............................................................................................................................... 40
Establish Binding Agreements with Partners .................................................................................................. 40
Chapter 6: Phase 2 - Analyze Data .................................................................................................................................. 42
6-1: Calculate Required Phosphorus Reduction .................................................................................................. 42
6-2: Determine Where and How to Reduce Phosphorus in Your Watershed.......................................... 43
Identify Vulnerable Lands ........................................................................................................................................ 43
Analyze Root Causes of Pollution .......................................................................................................................... 44
Evaluate and Prioritize Runoff Control Options ............................................................................................. 44
6-3: Determine How Actions Will Be Funded ....................................................................................................... 48
Cost-Sharing ................................................................................................................................................................... 48
Agricultural Conservation Programs ................................................................................................................... 49
Performance-Based Compensation ...................................................................................................................... 49
Applying for Grants ..................................................................................................................................................... 50
Chapter 7: Phase 3 - Create the AMO Plan .................................................................................................................. 51
7-1: Set Goals, Objectives and Indicators ................................................................................................................ 51
7-2: Develop Core Strategies for Your Plan ........................................................................................................... 53
Outreach Strategies ..................................................................................................................................................... 53
Collaborative Strategies ............................................................................................................................................ 56
Pilot Strategies .............................................................................................................................................................. 57
Verifying Compliance ................................................................................................................................................. 58
7-3: Develop the Implementation Plan .................................................................................................................... 59
Meet DNR Requirements for an AMO Plan ........................................................................................................ 59
Additional Resources for Developing the Plan ................................................................................................ 60
Chapter 8: Implement and Adapt the Plan .................................................................................................................. 63
8-1: Permit Requirements for the AMO................................................................................................................... 63
8-2: Monitor and Report Water Quality Data........................................................................................................ 63
8-3: Assess and Adapt the Plan Based on Results ............................................................................................... 64
Issue: Phosphorus load reduction goals aren’t being met .......................................................................... 64
Issue: The plan implementation is costing more than expected .............................................................. 65
8-4: Mitigating Risks of the AMO ................................................................................................................................ 66
Appendix A: Worksheet for Determining P Load Reductions ............................................................................. 68
Appendix B: Potential Partners ....................................................................................................................................... 70
Citizen Water Monitoring Programs .................................................................................................................... 70
County Land and Water Conservation Committees ...................................................................................... 70
County Land and Water Conservation Departments .................................................................................... 71
Department of Agriculture, Trade and Consumer Protection (DATCP)................................................ 71
Environmental Advocacy Groups .......................................................................................................................... 71
Hunter/Sportsmen’s Groups ................................................................................................................................... 72
Land Trusts..................................................................................................................................................................... 73
Natural Resources Conservation Service (NRCS) ........................................................................................... 73
Parks Departments/Public Works Departments ............................................................................................ 73
Regional Planning Commissions............................................................................................................................ 74
Schools and Higher Education ................................................................................................................................ 74
United States Fish and Wildlife Service (FWS) ................................................................................................ 75
United States Geographical Survey (USGS) ....................................................................................................... 75
University of Wisconsin Cooperative Extension ............................................................................................. 75
Watershed Associations/”Friends” Groups ...................................................................................................... 76
Wisconsin Department of Natural Resources .................................................................................................. 76
Wisconsin Rural Water Association (WRWA) ................................................................................................. 77
Appendix C: Funding Sources ........................................................................................................................................... 78
Clean Water State Revolving Fund (Environmental Improvement Fund) ........................................... 78
Conservation Innovation Grants............................................................................................................................ 78
Conservation Reserve Program/Conservation Reserve Enhancement Program ............................. 79
Conservation Stewardship Program (CSP) ....................................................................................................... 80
Environmental Quality Incentives Program (EQIP) ...................................................................................... 80
Great Lakes Restoration Initiative (GLRI) ......................................................................................................... 81
Mississippi River Basin Initiative Grants ........................................................................................................... 82
River Protection Planning and River Protection Management Grants .................................................. 82
Sustainable Agriculture Research and Education (SARE) Grants............................................................ 83
Targeted Runoff Management Grants ................................................................................................................. 83
Wildlife Habitat Incentives Program (WHIP) .................................................................................................. 84
Wisconsin Trout Unlimited Access Fund ........................................................................................................... 84
Additional Funding Information ................................................................................................................................ 85
Appendix D: Rural and Urban Practices for Reducing Phosphorus .................................................................. 86
Field Methods: Managing P Application to Reduce Runoff Risk ................................................................... 86
Barrier Methods: Preventing P from Reaching Waters .................................................................................... 87
Nutrient Management Plans ........................................................................................................................................ 88
Urban Runoff Management Practices ....................................................................................................................... 88
Introduction
Every year, phosphorus pollution takes a major toll on Wisconsin’s environment and economy.
According to the Wisconsin Department of Natural Resources (DNR), a fourth of the over 700
impaired water bodies in Wisconsin are impaired due to phosphorus.1 Excessive phosphorus in
lakes and streams causes blue-green algae growth, which affects water quality and can lead to fish
kills. Blue-green algae blooms can also be foul-smelling and even toxic to humans, pets and
livestock, decreasing quality of life, recreation and tourism on our waters.

In 2010, the DNR adopted regulations to address the phosphorus problem. This set of rules,
referred to collectively as the “phosphorus rule,” establishes the amount of phosphorus that can be
present in state waters without negatively affecting water quality. The rule also contains a
provision for phosphorus dischargers called the adaptive management option (AMO). This option
allows phosphorus dischargers within a given watershed to create a flexible, cost-effective strategy
for phosphorus reduction.

This handbook explains the AMO and the process of creating a phosphorus reduction plan. This
handbook is primarily targeted to operators at municipal wastewater treatment facilities, who will
be central to the AMO. However, the driving force behind the AMO is collaboration between
multiple entities, and this handbook contains information relevant to other involved groups. You
might find this handbook useful if:

 You are a municipal or industrial direct discharger considering or developing an AMO plan
for phosphorus, or a consultant working on a plan for a phosphorus discharger.
 You are a county conservationist, local government official, watershed or lake association
member or other stakeholder involved in implementing an AMO plan.
 You are considering the AMO and you need specific details about the process and its
benefits.

If you have questions about the information in this handbook, contact Clean Wisconsin
at amohelp@cleanwisconsin.org.

Note that the DNR provides a technical handbook that focuses on the regulatory requirements for
the AMO. This handbook, as well as other informational materials, is available
at http://dnr.wi.gov/topic/surfacewater/adaptivemanagement.html.

Acknowledgements

Clean Wisconsin is very grateful for the foundations who generously support our work, and have
provided funding for the development of this handbook. Thank you, Joyce Foundation and
McKnight Foundation; without your support, we would not be able to take on such important
projects.

Additionally, we are thankful for the time and effort by those who assisted with the production of
this handbook. The following reviewers provided valuable comments and suggestions for the

1 “Reducing Phosphorus to Clean Up Lakes and Rivers,” Wisconsin Department of Natural Resources,
2012, http://dnr.wi.gov/news/mediakits/mk_phosphorus.asp.
handbook: Andrew Aslesen and Chris Groh (Wisconsin Rural Water Association), Pat Cardiff
(Grande Cheese), Ken Genskow (University of Wisconsin-Extension), Bill Hafs (Brown County Land
and Water Conservation Department), Angela James (Wisconsin Paper Council), John Kennedy and
Tom Sigmund (Green Bay Metropolitan Sewerage District), Paul Kent (Stafford Rosenbaum), Brad
Klein (Environmental Law and Policy Center), Betsy Lawton (Midwest Environmental Advocates),
Amanda Minks (Wisconsin Department of Natural Resources), Steve Richter (The Nature
Conservancy), Kevin Shafer (Milwaukee Metropolitan Sewerage District), David Taylor (Madison
Metropolitan Sewerage District) and Jim Vandenbrook (Wisconsin Land and Water Conservation
Association).
Chapter 1: Overview of the Phosphorus Rule and the
Adaptive Management Option

In this section:
1-1: Background
The reasons for phosphorus standards in Wisconsin
1-2: How the AMO Works
A broad description of the framework of the AMO
1-3: AMO vs. Facility Upgrades
A comparison of the AMO and facility-level phosphorus control
technologies
1-4: Why the AMO Works
The benefits of the AMO and the reasons it can work to control
phosphorus pollution
1-5: How to Use This Handbook
The purpose of this handbook and information about other
resources for AMO planning

1-1: Background

In small doses, phosphorus (P) is a good thing. It’s necessary for organisms to grow, which is why
farmers apply it to their crops and homeowners apply it to their gardens. But in large doses, it can
cause problems for the exact same reason. Large amounts of phosphorus can cause too much plant
and bacteria growth, which can have drastic consequences. Excessive phosphorus is responsible for
the noxious blue-green algae blooms that appear on Wisconsin lakes in the summer, reducing
property values, causing fish kills and diminishing quality of life on the lakes for humans and
wildlife alike.

There are two types of phosphorus pollution, distinguished by their sources: Point source pollution
and nonpoint source pollution. Point source pollution has a specific origin, such as a discharge pipe
at a factory or outfall of a wastewater treatment plant. Nonpoint source pollution, meanwhile, has a
much broader area of origin or no specific source at all. Nonpoint source pollution can come from
cropland, grazing pastures, lawns, parks or any other area where phosphorus is applied, whether as
fertilizer or as organic waste. The excess phosphorus washes away with rain or snowmelt and
makes its way into adjacent bodies of water. Because nonpoint source pollution is by its nature an
aggregate of pollution from several origins, it is more difficult to monitor and control than point
source pollution.

In 2010, the DNR established standards for phosphorus levels in different types of water bodies,
whether from point or nonpoint sources. These standards establish how much phosphorus can be
in a body of water without causing negative effects, such as contributing to blue-green algae
growth. Information about the specific standards is in the Phosphorus Management and Regulation
in Wisconsin section of this handbook.
These standards affect facilities that are direct dischargers of phosphorus, which are required by
their permits to meet assigned limits on phosphorus levels in their discharge. Lower standards for
phosphorus in a water body result in stricter limits on the amount of phosphorus that a point
source may discharge into that water body. Traditionally, to achieve these limits, point sources
would upgrade their facilities or alter their operations to reduce the amount of phosphorus in the
facility’s discharge.

However, the prevalence of phosphorus pollution in Wisconsin’s waters would make it difficult for
point sources to achieve required water quality standards through facility upgrades alone.
According to an economic impact study performed by the DNR, the costs of facility upgrades for
state point sources to meet phosphorus standards could total approximately $1-2 billion.2
Additionally, facility upgrades do not directly address the issue of nonpoint source pollution, which
in many areas is the primary source of phosphorus.

As one strategy to lessen the overall cost of meeting stricter discharge limits, the phosphorus rule
includes a provision called the adaptive management option (AMO), which is a watershed-level
strategy that focuses on reducing phosphorus pollution from both point and nonpoint sources. In
the long run, this option may reduce more total phosphorus and save money for point sources
compared to traditional point-source phosphorus controls.

Note that you might see the term “adaptive management option” used interchangeably with the
term “adaptive management.” Keep in mind that the AMO differs from the general concept of
adaptive management, which has been an established approach to problem solving for decades. The
AMO refers specifically to the phosphorus control option defined in Wisconsin’s administrative
code, which is administered and regulated by the DNR. However, the AMO incorporates some of the
principles of adaptive management, such as continually evaluating and altering the plan based on
observed results.

1-2: How the AMO Works

The AMO provides a way for point source phosphorus dischargers to reduce phosphorus pollution
in their watershed without having to implement expensive technologies. The option is designed so
that point sources can help reduce phosphorus pollution across an entire watershed.

The AMO addresses nonpoint phosphorus pollution at its source, rather than down the line. The
option is structured around point sources of phosphorus pollution working with agricultural and
urban partners to limit nonpoint phosphorus runoff. For example, under an AMO plan, a municipal
sewerage district could provide resources to with farmers in the watershed to implement and
obtain funding for phosphorus-reducing agricultural practices, such as the construction of
vegetated waterways and filter strips designed to slow and absorb runoff from fieldsThis approach
provides a financial incentive to farmers to implement pollution control practices while reducing
phosphorus control costs for municipal and industrial phosphorus dischargers.

In some ways, the AMO is similar to water quality trading, in which point sources of phosphorus
purchase “credits” that represent a certain reduction in phosphorus pollution to offset the facility’s
discharge. In both strategies, the facility is supporting phosphorus-reducing practices to ease the

2“Phosphorus Reduction in Wisconsin’s Water Bodies: An Economic Impact Analysis,” Wisconsin Department
of Natural Resources, 2012, http://dnr.wi.gov/topic/SurfaceWater/documents/PhosphorusReductionEIA.pdf .
pressure of meeting strict water quality standards at the facility level. However, these two
strategies have different measures of compliance. In water quality trading, facilities are compliant if
they have purchased the number of verified credits proportionate to their phosphorus
discharge. In the AMO, facilities are compliant if their receiving water meets monitored water
quality standards. In this way, the AMO puts a greater emphasis on results than it does on specific
action. This focus also sets the AMO apart from traditional brick-and-mortar upgrades, which are
discussed in the next section.

1-3: AMO vs. Facility Upgrades

In some cases, the AMO is expected to be much less expensive than implementing phosphorus
reduction technology at the facility level. The specific costs of each option will be unique to each
facility and to each watershed, but existing studies and estimates can give an idea of the relative
costs of each option.

For example, the Madison Metropolitan Sewerage District (MMSD) is currently working on a pilot
project in Dane County to test out the AMO on a smaller scale. (More information about this project
is in the Pilot Strategies section of Chapter 7 of this handbook.) According to MMSD, which is a
facility with an average flow of 40 million gallons per day (MGD), the cost of traditional facility
upgrades to meet their required effluent limit would have been from $79 million-$124 million.3
Meanwhile, the pilot project is projected to cost $3 million and the full-scale project approximately
$59 million.

It’s not only total cost to consider, but cost-effectiveness as well. To use another example from
MMSD, the cost of the AMO versus constructing a stormwater retention pond worked out to be
approximately $27 per pound of phosphorus reduced through the AMO and $500 per pound for the
retention pond. Since brick-and-mortar upgrades to meet stringent phosphorus limits can be
expensive, watershed-scale phosphorus reductions can provide more “bang for your buck” than
end-of-pipe reductions.

The AMO has the benefit of addressing nonpoint phosphorus pollution at its source, rather than
further down the line where phosphorus can be more concentrated and more difficult to treat. It
addresses the watershed-level problem of phosphorus pollution at the most effective scale: the
watershed. Compared to the narrower focus of facility upgrades, the AMO may be a more
comprehensive and therefore more enduring solution to phosphorus pollution.

1-4: Why the AMO Works

The AMO is a unique approach to water conservation in that it involves using a variety of means to
achieve a specific end. Traditional conservation strategies have used specific means (such as
placing a limit on effluent phosphorus from a point source) to achieve a nonspecific end (such as
improving water quality in general). Such strategies focus on phosphorus control at the scale of
individual facilities rather than at the scale of the watershed. At the facility scale, it’s difficult to
control for phosphorus contributions from nonpoint sources.

3 Dave Taylor, personal communication, 2012.

The AMO flips traditional strategies around to focus on specific results: meeting water quality
standards for phosphorus. There are no prescribed means of meeting specific water quality
standards, but those specific standards must be attained. Because water quality standards can be
the basis for facility-level discharge limits, the AMO may ease the pressure on point sources by
improving water quality across the watershed in the long run.

Since it can be a more cost-effective way to achieve required water quality standards, point source
dischargers of phosphorus may directly benefit from the AMO. Meanwhile, there are potential
indirect benefits of controlling all sources of phosphorus. Less blue-green algae in our lakes
benefits tourism, lakeshore property values and water recreation. Healthier water benefits fish and
wildlife and the sportsmen who depend on them. More sustainable farming practices benefit food
producers and consumers. The AMO can be the best approach communities can take to protect the
long-term health of their watershed.

1-5: How to Use This Handbook

The main purpose of this handbook is to provide a starting point and continuing reference source
for organizations developing an AMO plan. It is not a substitute for facility-specific research or
analyses. There is no one correct way to implement the AMO, so this handbook does not provide
one specific set of directions. Instead, this handbook contains explanations of aspects of the AMO,
recommendations for implementation, case studies, reference materials and contact information
for additional resources. You can use this handbook to determine what information you need to
develop an AMO plan and where to find that information.

Audience

Many different stakeholders will be involved in developing AMO plans, including point source
permittees, county executives, consultants, conservation staff and nonprofit organizations, to name
a few. This handbook can provide background information, procedural directions and
recommendations for any stakeholder developing a plan or considering the AMO.

For simplicity, this handbook is primarily addressed to operators at municipal wastewater

treatment facilities, who will be one of the main players in the AMO. “You” refers to these operators,
but can also apply to other stakeholders, such as industrial point sources and local government
officials. To avoid confusion, this handbook addresses singular facilities, but these references can
also apply to groups of facilities working together.

Additional Resources

This handbook is not the only source of information about AMO implementation or planning. In this
handbook you’ll find several cross-references and links to other resources. If you’re reading this
handbook as a PDF or print copy, the web addresses are included in full. Web addresses are
accompanied by the title of the resource if you prefer searching or if the link isn’t working.

The Wisconsin DNR has a set of reference materials for phosphorus standards and options for
meeting them. This handbook occasionally refers to DNR materials for further explanation of
technical topics that are beyond this scope of this handbook. You can find the DNR phosphorus
guidance document online
at http://dnr.wi.gov/topic/SurfaceWater/documents/Phosphorus_Guidance_Signed.pdf (Title:
Guidance for Implementing Wisconsin's Phosphorus Water Quality Standards for Point Source
Discharges). Additionally, the DNR has a technical handbook for meeting the requirements for the
AMO. The technical handbook is available
at http://dnr.wi.gov/topic/surfacewater/adaptivemanagement.html (Title: Adaptive Management
Technical Handbook).

The U.S. EPA also has an extensive handbook about watershed planning. It is broadly directed at
anyone developing any type of watershed plan, and some of the information may be beyond the
scope of your project. A comprehensive watershed plan isn’t required for the AMO, but the U.S.
EPA’s handbook contains tools that can be useful in data gathering and planning for the AMO. This
handbook is available at http://water.epa.gov/polwaste/nps/handbook_index.cfm (Title:
Handbook for Developing Watershed Plans to Restore and Protect Our Waters).
Chapter 2: Watersheds and Phosphorus in Wisconsin
This section provides the environmental and regulatory context for watershed management
in Wisconsin.

This chapter is intended for readers with limited background on watershed science and regulation in
Wisconsin. If you already have a good understanding of these topics, you can skim or skip this chapter.

In this section:
2-1: Overview of Watersheds
Definitions of watersheds and related terms
2-2: Water Quality Standards and Regulations
An overview of water quality standards and total maximum daily
loads (TMDLs)
2-3: Phosphorus Management and Regulation in Wisconsin
An explanation of the sections of the Wisconsin state
administrative code related to phosphorus control

2-1: Overview of Watersheds

A watershed is a geographic area where all bodies of water drain to the same endpoint, such as a
lake or river. For this reason, watersheds are sometimes referred to as drainage basins. The
watershed boundary is typically marked by areas of higher elevation, so waters flow downhill
toward the endpoint.

However, what constitutes a watershed varies based on the scale of a given area and the defined
endpoint. A given river might be the endpoint of one area, but that river in turn drains into a larger
river, and so on. As an extreme example, the Mississippi River watershed covers 32 states and
includes water bodies between the Rocky Mountains and the Appalachians, draining into the Gulf of
Mexico.

Different terms are typically used to distinguish watersheds of different sizes. During your research
and planning, you’ll most likely encounter the following terms:

 Basin
 Sub-basin
 Watershed
 Sub-watershed

These terms can overlap, but in general the term used corresponds to the size of the area – the list
above is in order from largest area to smallest area. Because the definitions and boundaries of
basins and watersheds can vary, regulatory agencies use a classification system that assigns
hydrologic unit codes (HUCs) to identify discrete watersheds and basins. You don’t need to know
the technical ins and outs of HUCs, but be aware that you might come across this terminology while
gathering watershed data. For example, DNR requirements for AMO planning refer to HUC sizes.
If you don’t know the basin or watershed you’re located in, go to the What Is My Watershed?
section in Chapter 5 for an overview of watershed identification tools.

Water bodies in a watershed can also be subdivided into discrete units for ease of classification and
evaluation. A designated stretch of a river or stream is called a reach. For example, chapter NR 102
of the Wisconsin Administrative Code applies a specific water quality criterion for a reach of the
Brule River “from state highway 55 in Forest County downstream to Menominee River.”

2-2: Water Quality Standards and Regulations

To control water pollution, there are several federal and state laws that designate maximum
acceptable pollutant levels in water bodies and how much of a given pollutant is allowed in point
source facilities’ discharges. This section goes over some of the major water quality standards
related to phosphorus pollution in Wisconsin and the permits that regulate phosphorus discharges.
These standards and regulations, which have been applicable in Wisconsin for decades, form the
basis of the phosphorus rule.

Types of Water Quality Standards

Under the Clean Water Act, the major federal law regulating water quality, the U.S. EPA establishes
standards for water quality in several areas, including aquatic life, nutrients and
pathogens. Additionally, as required by the Clean Water Act, the Wisconsin administrative code
assigns four designated uses to Wisconsin water bodies: Recreation, Wildlife, Fish and Aquatic Life
(FAL) and Public Health and Welfare. Designated uses describe the activities that a given body of
water and the activities should be able to support, such as fishing or providing habitat for native
species. These criteria are often simply referred to as “fishable/swimmable.” According to the
Wisconsin administrative code, all of the state’s surface waters should support the four designated
uses unless otherwise specified.4

Wisconsin has a further subset of waters identified as Outstanding or Exceptional Resource Waters
(ORW and ERW). You might encounter these terms for certain water bodies in your watershed.
These waters are considered particularly important to the state for their aesthetic, recreational or
ecological qualities, and therefore they receive more protections than other water bodies. ORWs,
the highest designation, typically do not receive discharges from point sources, while ERWs do. For
their protection, ORWs and ERWs have stricter associated permitting requirements.5

The Clean Water Act also requires states to create lists of impaired waters and to submit those lists
to the U.S. EPA every two years. Waters are defined as impaired if they don’t meet the water quality
standards defined by federal or state law or if they are not suitable for their designated use. For
example, if a body of water contains an algae bloom that makes it unsafe for swimming or other
body contact, the water doesn’t meet its designated use of Recreation. The list of impaired waters is
known as a 303(d) list for the section of the Clean Water Act that requires it.

To address sources of pollution in impaired waters, there are several different types of water
quality standards and pollutant limits. Below are some common terms you’ll encounter in this

4 Wis. Adm. Code NR § 102.04, https://docs.legis.wisconsin.gov/code/admin_code/nr/102/I/04.

5“Outstanding and Exceptional Resource Waters,” Wisconsin Department of Natural Resources, last modified
April 24, 2012,http://dnr.wi.gov/topic/SurfaceWater/orwerw.html.
handbook and in other steps of AMO planning. Although these limits can apply to any water
pollutant, for the purpose of this handbook they’ll always refer to phosphorus loads.

 Technology-based limits (TBLs) are restrictions on the amount of phosphorous that a

facility may discharge based on the treatment technology available to the facility. TBLs are
determined based on the best available and economically feasible treatment technologies
that the facility could employ. For publicly-owned treatment works (POTWs), the limit is
based on the type of secondary (biological) controls that the facility could use to reduce
effluent phosphorus.

 Water quality-based effluent limits (WQBELs) are restrictions on the amount of phosphorus
that a facility may discharge based on the phosphorus levels in the water body that receives
the facility’s effluent (the receiving water). WQBELs are typically more stringent than TBLs.
An explanation of WQBEL calculation in Wisconsin is in the Obtain Your Facility’s
Phosphorus WQBEL section in Chapter 4 of this handbook.

 Total maximum daily loads (TMDLs) are U.S. EPA-approved restrictions on the amount of
phosphorus that a body of water may receive each day and still maintain acceptable
phosphorus levels. TMDLs differ from the first two limits described above in that they apply
to an entire water body and not a point source of phosphorus. In a TMDL, all phosphorus
contributors in the TMDL area are identified and assigned mass limits on the amount of
phosphorus that each contributor may discharge daily. (For point sources, this limit is
called a wasteload allocation or WLA.) If there is a TMDL established for a body of water,
facilities that discharge into that body of water are assigned WQBELs back-calculated from
the wasteload allocation in the TMDL.

TMDL reports include comprehensive descriptions of the watershed and recommendations

for management. These reports can be a valuable starting point for an AMO plan. Visit the
DNR website for additional information about TMDLs in Wisconsin.

Discharge Permits

The above limits and other regulations are outlined in discharge permits, which dictate how point
source facilities may discharge pollutants into water bodies. The U.S. EPA issues discharge permits
under the National Pollutant Discharge Elimination System (NPDES). In Wisconsin, these permits
are called Wisconsin Pollutant Discharge Elimination System (WPDES) permits and are
administered by the Wisconsin DNR. A WPDES permit term is five years long.

Variations on WPDES permits

WPDES permits vary based on the type of permitted facility or entity. For example, a wastewater
treatment facility discharges pollutants differently than a large agricultural operation. When this
handbook refers to permits, it generally applies to WPDES permits issued to wastewater treatment
facilities or industrial phosphorus dischargers. However, unique WPDES permits are also issued to
the following types of operations:

Concentrated animal feeding operations (CAFOs) The Wisconsin DNR defines CAFOs as livestock
feeding operations that have 1000 or more animal units (roughly equivalent to 700 milking and dry
dairy cows) or that discharge waste into navigable waters or wells.6 Operations designated as
CAFOs must have a WPDES permit.

CAFOs operate as both point and nonpoint sources of phosphorus. Under a CAFO permit, there
generally must be zero pollutant discharge from the immediate site of the livestock operation.
However, CAFO operators typically dispose of animal waste by spreading it on fields. The runoff of
land-applied waste is considered nonpoint pollution, and it is regulated differently than feedlot
waste. CAFO permits regulate the amount and timing of this manure spreading.

Municipal separate storm sewer systems (MS4s) These systems, which can include structures like
gutters, channels and storm drains, collect and divert surface runoff after rainfalls in urban areas.
Unlike municipal wastewater or industrial permits, MS4 permits do not typically contain specific
effluent limitations for phosphorus7 – phosphorus load limits are assigned to MS4s only in areas
with a TMDL for phosphorus. Instead, MS4 permits outline management measures required of the
MS4 operator, including public outreach campaigns and plans for addressing illicit discharges.

MS4s are somewhat of a mix between nonpoint and point sources of pollution. They collect runoff
from many nonspecific sources, such as lawns, roads and parking lots, but discharge from specific
points. MS4s are technically considered point sources, which is why their operators have to obtain a
discharge permit. However, for the purposes of the AMO, MS4 discharges are treated similarly to
nonpoint sources. Municipal stormwater is considered nonpoint source pollution when assessing
different sources of phosphorus in a watershed.

Even if MS4 operators are not required to meet effluent limitations for phosphorus, their permit
requirements and existing outreach programs could be an asset to an AMO plan. For example,
efforts to engage the public in runoff prevention and to control suspended solids could reduce
urban contributions to total phosphorus in the watershed.

2-3: Phosphorus Management and Regulation in Wisconsin

Although the AMO and related phosphorus standards are new as of 2010, phosphorus management
is not new to Wisconsin. Before the passage of the current phosphorus rule, the state already had
regulations in place to control agricultural and urban nutrient pollution. This section goes over the
new phosphorus rule as well as the Phosphorus Index, one of the main tools used in nutrient
management in Wisconsin that will be a central part of planning for the AMO.

Wisconsin’s Phosphorus Rule

In December 2010, in response to the growing problem of phosphorus pollution in Wisconsin, the
DNR adopted several regulations regarding phosphorus management, known together as the
phosphorus rule. The following sections of the Wisconsin administrative code lay out phosphorus
regulations in Wisconsin and provide an outline for management strategies.

6 “Concentrated Animal Feeding Operations,” Wisconsin Department of Natural Resources, last modified
November 14, 2012,http://dnr.wi.gov/topic/AgBusiness/CAFOgeneralInfo.html .
7 “Municipal storm water permit overview,” Wisconsin Department of Natural Resources, last modified May 7,

2012,http://dnr.wi.gov/topic/stormwater/municipal/overview.html .
NR 102.06 establishes the maximum concentration of phosphorus allowed in various types of water
bodies. The following standards apply:8

 Rivers: 100 μg/L (0.1 mg/L)

 Streams: 75 μg/L (0.075 mg/L)
 Lakes: 15-40 μg/L (0.015-0.040 mg/L)
 Reservoirs: 30-40 μg/L (0.030 – 0.040 mg/L)

Water quality standards, which apply to entire water bodies, are not to be confused with effluent
limits, which apply only to a permitted facility’s discharge. The effluent limits assigned to permitted
phosphorus dischargers will be based on an equation in the phosphorus rule that takes the
receiving water’s target phosphorus level into account.

NR 151 outlines procedures for managing polluted runoff and places restrictions on agricultural
practices that can contribute to runoff. For example, here are some example regulations relevant to
phosphorus runoff control:9

 NR 151.03 states that a landowner may not till fields in a way that degrades stream bank
 NR 151.04 states that the Phosphorus Index (see the following section) of cropland,
pastures or winter grazing land must average 6 or below.
 NR 151.08 states that livestock producers must not allow manure to overflow or to directly
run off of feedlots or manure storage facilities into state waters.

Chapter NR 151 also includes procedural guidelines for regulation and enforcement of runoff
management standards.

NR 217 provides the basis for establishing phosphorus limitations and meeting them with the
AMO.10

 NR 217.13 provides the calculations for determining WQBELs for permittees.

 NR 217.18 outlines the AMO and the criteria to be eligible for this option.

You’ll find more detailed explanation of various parts of the administrative code in this handbook.
However, for a technical breakdown of each of the sections of the phosphorus rule and its
associated calculations, refer to the DNR phosphorus guidance document or to the linked
legislation.

Wisconsin Phosphorus Index

A vital part of phosphorus management in Wisconsin is the Phosphorus Index (also called the P
Index or PI). The P Index is a value generated by SNAP-Plus (a computer-based modeling tool) and
used to estimate the amount of phosphorus lost from land. For several years, the P Index has guided
the development of nutrient management plans for farmers. Wisconsin’s phosphorus standards
required that producers apply manure only to fields with a P Index of 6 or below, since fields with a
higher P Index have a greater risk of significant phosphorus runoff.

8 Wis. Adm. Code NR § 102.06, https://docs.legis.wisconsin.gov/code/admin_code/nr/102/I/06.

9 Wis. Adm. Code NR § 151, https://docs.legis.wisconsin.gov/code/admin_code/nr/151.
10 Wis. Adm. Code NR § 217, https://docs.legis.wisconsin.gov/code/admin_code/nr/217.
The P Index will be an essential tool in determining which fields in your watershed contribute the
highest amounts of phosphorus to area waters or which fields have the greatest risk of phosphorus
runoff. Additionally, the P Index can inform the types of practices that can reduce the runoff
risk. This information can help you determine the action area and prioritize the location of
phosphorus-reducing practices. Your county conservation department or local NRCS staff may
assist you in determining areas with a higher P Index in your watershed.

Find out more about the P Index and its applications at http://wpindex.soils.wisc.edu.
Chapter 3: Process and Timelines for the AMO
Timelines for the AMO will vary depending on where you are in the planning process. You may be
reading this handbook as you initially consider the AMO for your community, or you may have
already begun planning and implementation. This chapter provides an overview of the timelines for
the AMO assuming that you are still in the exploratory phases, but you can skip ahead to later steps
if you have already made progress on the AMO.

This section also outlines the general process of planning and implementing the AMO, but keep in
mind that this will not necessarily be a linear, chronological process. Depending on time and
resources available, different planning and implementation actions could occur out of order or
simultaneously. Additionally, the timing for planning or implementation might overlap
inconsistently with the DNR’s regulatory timelines. For this reason, this chapter is divided into two
different timelines: regulatory and planning.

In this section:
3-1: Regulatory Timelines
The schedule outlined by the DNR for developing and submitting
AMO plans.
3-2: Planning Timelines
The general outline for designing, implementing and maintaining
an AMO plan.

3-1: Regulatory Timelines

This section goes over the steps required by the DNR for developing an AMO plan and what you
need to do for each step. For additional clarification, the DNR’s technical handbook for the AMO also
includes timelines for the AMO.

The steps in this section will be required of all facilities implementing the AMO. However, the
permit term in which these steps occur will depend on whether or not the facility is granted a
compliance schedule, explained below.

Compliance Schedules

If a facility is assigned a stringent phosphorus WQBEL, the facility may be granted a compliance
schedule, a defined period of time to comply with water quality-based effluent limits for a given
pollutant. (In this handbook, compliance schedules are assumed to apply to phosphorus limits.)
Without a phosphorus compliance schedule, the WQBEL will take effect as soon as the permit is
issued or reissued. With a compliance schedule, the WQBEL will take effect at the end of the
compliance schedule. For example, if a facility has its permit reissued on January 1, 2014 and is not
granted a phosphorus compliance schedule, the WQBEL will take effect on January 1, 2014. If the
facility is granted a seven-year compliance schedule, the WQBEL will not take effect until January 1,
2021. During the period of a compliance schedule, a facility must complete specific interim steps as
outlined in the permit.

Compliance schedules are designed so a facility can comply with its phosphorus WQBEL as soon as
possible. Facilities may be granted compliance schedules of up to nine years if filtration would be
required to meet the facility’s assigned effluent limit. Before the final WQBEL takes effect at the end
of the compliance schedule, the facility will need to comply with an interim phosphorus limit as
specified in its WPDES permit.11

One purpose of a compliance schedule is to allow time for facilities to evaluate the available options
to meet the assigned WQBEL, including the AMO.12 However, a compliance schedule is not always
necessary for evaluating options or developing an AMO plan. Regardless of whether your facility is
granted a compliance schedule or not, we recommend evaluating the AMO and developing a
plan as soon as resources allow. Ideally, you’ll develop and submit an AMO plan request with
your facility’s first permit reissuance that includes the stringent WQBEL. The sooner you develop an
AMO plan and have it approved, the sooner you can implement phosphorus-reducing practices.

To pursue the AMO, you will take the steps below regardless of whether your facility is granted a
compliance schedule or not.

Steps for Developing and Submitting an AMO Plan

Step 1: Obtain your facility’s stringent WQBEL

What you need to do: Determine your facility’s phosphorus WQBEL by requesting it from the DNR
or calculating it yourself. (If you’re in the process of permit reissuance, consult your permit fact
sheet for your WQBEL.) A stringent WQBEL (considered by the DNR to be lower than 0.6 mg/L for
mechanical plants or lower than 1.5 mg/L for ponds and lagoons) is one of the first indicators that
the AMO could be an appropriate phosphorus control option for your facility.

The DNR will provide you with your facility’s phosphorus WQBEL at or before permit reissuance,
but we recommend proactively obtaining the phosphorus WQBEL to allow more time for evaluating
and planning phosphorus control strategies. For information on requesting or calculating the
phosphorus WQBEL, refer to the Obtain Your Facility’s Phosphorus WQBEL section of this
handbook.

Step 2: Determine eligibility for the AMO

What you need to do: Gather data about your facility and watershed to prove that you meet the
AMO’s eligibility requirements, which are outlined in NR 217.18(2) and also explained in Chapter
4 of this handbook.

To officially verify eligibility for the AMO, you will fill out the DNR’s Watershed Adaptive
Management Request Form and select the “This is a preliminary adaptive management request”
option. The preliminary request form requires information about your facility’s operation and the
scope of nonpoint phosphorus pollution in your watershed.

11 Wis. Adm. Code NR § 217.17, http://docs.legis.wisconsin.gov/code/admin_code/nr/217/III/17.

12 "Guidance for Implementing Wisconsin's Phosphorus Standards for Point Source Discharges," page 57.
After the preliminary request is approved, verifying that your facility is eligible for the AMO, you
will develop a complete AMO plan. The reason we recommend submitting the preliminary request
several years prior to your next permit reissuance is to allow sufficient time to develop the full plan.

Step 3: Submit a formal AMO request

What you need to do: Complete the DNR’s formal Watershed Adaptive Management Request
Form, which requires more information than the preliminary request. To complete the form, you’ll
need to include information like the major sources of phosphorus pollution in your watershed,
partners in your AMO plan and funding sources for implementation.

If approved, the AMO plan will be incorporated into your facility’s WPDES permit. Permits that
include AMO plans, like other WPDES permits, will have a public comment period for review before
they take effect. Permits on public notice are available on the DNR website
athttp://dnr.wi.gov/topic/wastewater/publicnotices.html (Title: WPDES permits on public notice).

Step 4: Implement the plan to meet interim limits and final WQBELs

What you need to do: Ensure that your facility meets the interim limits or final WQBEL in your
permit for each permit term. After an approved AMO plan has been incorporated into your facility’s
WPDES permit, you will have a maximum of three permit terms (15 years) to meet the final
WQBEL. During these permit terms, the following effluent limits will apply:

 Permit term 1: ≤ 0.6 mg/L (six-month average) or 1.0 mg/L (monthly average)
 Permit term 2: ≤ 0.5 mg/L (six-month average) or 1.0 mg/L (monthly average)
 Permit term 3: Final WQBEL13

The specific interim and final limits will vary from facility to facility, so keep in mind that the values
above are the maximum possible based on state rules and that the limits at your facility may be
different. Meeting interim effluent limits will require changes at the facility scale, such as
optimization or upgrades.

However, an important benefit of the AMO to keep in mind is that the final WQBEL, because it’s
based on water quality, can be recalculated based on improvements to your facility’s receiving
water over the course of your AMO plan implementation. If the phosphorus-reducing measures you
take result in lower phosphorus levels in your receiving water, your facility’s initially assigned
WQBEL can be relaxed.

3-2: Planning Timelines

While your facility is completing the required regulatory steps for the AMO, you’ll also be following
a timeline for AMO plan development. The required and recommended steps for AMO planning are
explained in the remainder of this handbook. In general, the planning process can be divided into
three phases:

 Phase 1: Gather Data and Build Partnerships

 Phase 2: Analyze Data

13 Wis. Adm. Code NR § 217.18(3)(e), http://docs.legis.wisconsin.gov/code/admin_code/nr/217/III/18 .

  Phase 3: Create the AMO Plan

Unlike the regulatory steps, it’s not required to follow a strict linear timeline while developing your
plan. However, this general outline is recommended. Your plan needs a solid basis in current,
complete data and strong partnerships. Then, careful data analysis can help prevent problems
during and after plan implementation. Due to the nature of adaptive management, you’ll return to
this three-phase framework as you assess results and adapt the plan. It’s also likely that you’ll add
partners and gain additional data as you advance in your plan, in which case you can adjust earlier
steps in the plan even if you’re farther along in planning or implementation.

The actual amount of time required for each phase will vary between facilities based on the amount
of existing data and the available resources. It will also depend on the size of the action area for the
AMO and the number of entities involved. Because of this variability, this handbook does not
include specific time estimates, and instead recommends starting to evaluate and plan for the AMO
as soon as possible.
Chapter 4: Determine Eligibility for the AMO
Although the AMO can be the right choice for many point source facilities, it’s not right for
everyone. The AMO is a large undertaking with several criteria for eligibility, and it requires access
to several resources and partners. Depending on the facility or the watershed, water quality trading
or facility upgrades may actually be a more feasible strategy, at least in the near future.

However, because so many watersheds in Wisconsin are affected by nonpoint source pollution, the
AMO and its focus on reducing nonpoint pollution can be the best available long-term solution in
many cases. This chapter explains the criteria for eligibility for the AMO and resources available to
you for determining whether your facility meets the criteria.

In this section:
4-1: Eligibility Requirements for the AMO
An overview of the criteria that must apply to your facility for
you to qualify for the AMO
4-2: Establish a Baseline Phosphorus Exceedance
Prove that phosphorus levels in your facility's receiving water
exceed standards for its type of water body
4-3: Determine Proportion of Nonpoint Phosphorus Pollution in
Receiving Water
Show that nonpoint phosphorus pollution must be controlled for
water quality standards to be met.
4-4: Obtain Your Facility’s Phosphorus WQBEL
Request or calculate your facility’s upcoming phosphorus
WQBEL to determine whether you meet the AMO criterion of a
stringent limit.
4-5: Describe Your Facility Operation
Explain the processes your facility uses to treat phosphorus.
4-6: Evaluate Your Watershed for the AMO
Determine whether your watershed's characteristics make it a
good fit for the AMO.

4-1: Eligibility Criteria for the AMO

At a basic regulatory level, your facility must meet all of the following criteria to be eligible for the
AMO:14

 There must be an exceedance of phosphorus in your facility’s receiving water. (That is, the
receiving water must have phosphorus levels above the phosphorus standards specified for
that type of water body in NR 102.)

14 Wis. Adm. Code NR § 217.18(2), https://docs.legis.wisconsin.gov/code/admin_code/nr/217/III/18 .

  50 percent or more of the phosphorus in your facility’s receiving water must be from
nonpoint sources (including MS4s), OR your facility’s limit demonstrably can’t be attained
without reduction of nonpoint source pollution.
 The water quality-based effluent limit (WQBEL) for your facility would require filtration or
an equivalent technology to achieve.

If you qualify for the AMO and you decide to pursue the option, you must submit an AMO plan that
includes all of the following features:15

 An analysis of the amount of phosphorus that your facility discharges and the point and
nonpoint sources of phosphorus pollution in your watershed
 Goals for phosphorus reduction and measures for determining whether the actions taken
are sufficient for reducing phosphorus to levels deemed acceptable by the state
 Identification of partners who will help you achieve your goals and the level of involvement
that each partner will have
 Demonstrated sufficient funding to achieve the goals

Keep in mind that these criteria are the basic regulatory requirements for the AMO, and there are
other factors that go into choosing the AMO for your facility. For example, a significant indicator of
the likelihood of success for an AMO plan is the presence of able and willing partner organizations,
such as other point sources, lake associations or nonprofit groups, in your watershed. Although this
isn’t a requirement for the AMO, it’s a strong recommendation. The end of this chapter summarizes
some of the watershed-level factors in selecting the AMO.

4-2: Establish a Baseline Phosphorus Exceedance

The most basic requirement for eligibility for the AMO is an exceedance of phosphorus in your
facility’s receiving water. If you’re considering the AMO, you likely already know that there is a
phosphorus exceedance. In any case, you should still determine the current phosphorus level in
your facility’s receiving water. Not only will this prove one eligibility criterion for the AMO, but it
will also establish baseline phosphorus levels so you’ll have an initial benchmark for measuring
progress in your plan.

There are several ways you can determine a baseline phosphorus level in a water body. At the time
of your facility’s permit reissuance, the permit reissuance fact sheet might include this information.
If not, or if you want to determine eligibility for the AMO prior to your next permit reissuance, you
can consult sources like DNR wastewater engineers or specialists or use online tools to find
phosphorus levels in your facility’s receiving water. If resources allow, you may also collect water
quality data yourself.

Real-World Example: Establishing a Baseline in the Yahara Watershed

The Yahara pilot project relied on the best professional judgment of external partners for several
steps in the AMO planning process, including the determination of a baseline phosphorus level.
MMSD contracted with a water resource engineering firm, Montgomery Associates, and the Dane
County conservation department to calculate the phosphorus baseline. Although existing

15 Wis. Adm. Code NR § 217.18(2), https://docs.legis.wisconsin.gov/code/admin_code/nr/217/III/18 .

phosphorus data was included in the Rock River TMDL (which includes the Yahara watershed),
project planners determined that this data was too outdated to use as a baseline. Instead, a
combination of SWAT and SNAP-Plus models were used to update the old TMDL data with more
recent data to establish a new, more accurate baseline phosphorus level for MMSD.

Rationale:

 The Dane County conservation department already had most of the data needed to
determine the baseline.
 This work did not have to be performed internally by MMSD's staff.
 The new calculated baseline is more representative of current conditions than data in the
TMDL report, which included older data collected before more recent land use changes and
is on a much larger scale than the pilot watershed.
 More accurate data from professionals specifically hired to conduct this type of analysis.

Considerations:

 Landowners may be hesitant to provide farm-specific information out of concerns about

privacy of data.
 Contracting with outside sources comes with additional costs.

Surface Water Data Viewer (SWDV)

You can use the SWDV, a tool provided by the DNR, to determine whether there is an exceedance of
phosphorus in your facility’s receiving water. The SWDV can also give you the initial background
phosphorus level of a water body when you are calculating necessary load reductions.16 If you’re
using the worksheet in Appendix A to determine your facility’s necessary phosphorus load
reductions, the SWDV can supply the information for line D (provided that monitoring data exists
upstream of your facility’s outfall).

Be aware that for certain layers to appear, there must be existing data for the selected point on the
map. For example, if you select the Calculated Total Phosphorus Data (NR217) layer, and the DNR
doesn’t have TP data for a given point on the map, that data won’t appear in the Results window
when you click on that point. If data doesn’t exist in the SWDV, or if existing data is old or
incomplete, you can consult local wastewater engineers or specialists, adaptive management
coordinators or different water quality databases to determine what, if any, water quality data is
currently available.

You can use layers to view a wide variety of data, but some layers are particularly useful for
gathering data for the AMO. The following layers can help you determine whether you meet AMO
criteria:

 Impaired Water Category. Per the Clean Water Act, all water bodies listed as 303(d)
Impaired Waters are categorized based on the main pollutant source. If the value for this

16 Guidance for Implementing Wisconsin’s Phosphorus Water Quality Standards for Point Source Discharges , page
92.
 category is NPS or PS/NPS blend, you have evidence that the receiving water meets the first
criterion for the AMO (both nonpoint and point sources contribute to phosphorus
exceedance).
 Impaired Water Status. This value specifies whether there is an existing or proposed
management plan for the water body, if impaired. You can use this data to determine
whether the water body has a U.S EPA-approved TMDL (status: TMDL Approved) or if there
is a TMDL in the works. If there is a TMDL for the water body, you can use the TMDL to
determine your facility’s WQBEL.

For additional information about using the SWDV, access the DNR’s help materials
at http://dnr.wi.gov/topic/surfacewater/datasets/swdv_help (Title: Surface Water Data Viewer
Help Page).

4-3: Determine the Proportion of Nonpoint Phosphorus Pollution in

Receiving Water

After determining that there’s a phosphorus exceedance in your facility’s receiving water, the next
step is determining where the phosphorus is coming from so you can prove that nonpoint source
phosphorus reductions are necessary to achieve water quality standards. This step will most likely
require assistance from external sources with significant monitoring or modeling capacity.

However, this step might have already been done for you. The DNR has already analyzed many of
the state’s permitted point sources of phosphorus and determined whether their watersheds are
dominated by nonpoint source pollution. The table of the DNR’s PRESTO results is available from
the following website: http://dnr.wi.gov/topic/surfacewater/presto.html (Title: Pollutant Load
Ratio Estimate Tool). Click the Nonpoint Source Dominated Facility Lookup link to open a
spreadsheet of the facilities for which PRESTO has been run. If the Nonpoint Source Dominated?
column for your facility has a Yes, your facility has satisfied the nonpoint source criterion for the
AMO.

Even if you can’t prove that nonpoint source pollution accounts for at least 50 percent of the total
phosphorus pollution in your watershed, you still can be eligible for the AMO if you can
demonstrate that your facility’s WQBEL cannot be met without controlling nonpoint pollution. You
can contact local wastewater engineer or specialists and regional adaptive management
coordinators if you have questions about this step.

4-4: Obtain Your Facility’s Phosphorus WQBEL

The WQBEL for your facility’s upcoming permit term is one of the criteria for determining whether
you are eligible for the AMO. To meet the effluent limit requirement for the AMO, one of the
following limits must apply to your facility:

 A WQBEL of 0.40 mg/L* or below, OR

 A WQBEL above 0.40 mg/L that demonstrably cannot be achieved without filtration or an
equivalent technology.
*Although not specifically outlined in the criteria for the AMO, 0.40 mg/L is the threshold identified by
the DNR as the effluent limit at or below which filtration will be required to remove phosphorus from
effluent. Essentially, a WQBEL of 0.40 mg/L or below signifies that extensive technology upgrades
would be required to meet the limit and that the permittee meets that criterion for the AMO.

The DNR will provide you with a WQBEL at or before the time of permit reissuance. However, we
recommend that you obtain the WQBEL for your facility’s upcoming permit term as far in advance
of the next permit term as possible. Knowing the upcoming WQBEL will help you determine
eligibility for the AMO and begin planning and implementation. The DNR has a guidance on the
process for requesting effluent limits available at
http://dnr.wi.gov/topic/wastewater/LimitsRequests.html (Title: Guidance for requesting effluent
limits for wastewater facility planning studies). After submitting your request, you’ll receive a limit
fact sheet with a calculation and explanation of the new WQBEL.

According to the phosphorus rule, the WQBEL for a given point source that discharges into a stream
or river is calculated from either a U.S. EPA-approved TMDL for the receiving water or from an
equation outlined in NR 217.13.17 The DNR phosphorus guidance also contains an explanation of
WQBEL calculation in section 2.01. Meanwhile, for facilities that discharge into an inland lake or
reservoir, the WQBEL is set equal to the phosphorus water quality standard for that water body.

One of the benefits of the AMO is that a given facility’s WQBEL can become less stringent if
phosphorus from other sources is controlled through the AMO. For example, if reductions in
nonpoint phosphorus pollution result in lower phosphorus concentrations upstream of the facility’s
discharge, the facility’s WQBEL might be relaxed. This process takes some of the pressure off of
individual facilities and can save money for the facilities by preventing the need for expensive
brick-and-mortar upgrades.

4-5: Describe Your Facility’s Operation

To demonstrate that your facility is eligible for the AMO, you need to provide a summary of your
facility’s operation and current phosphorus removal technologies. This section is similar to facility
descriptions from existing WPDES permits, so you likely have much of this information available
already.

The AMO request form asks for the following information about your facility:

 Effluent phosphorus levels from at least the past three years. This information should
already be part of existing WPDES permits.
 Your facility’s design capacity
 A description of the treatment process
 If your upcoming WQBEL is over 0.4 mg/L, you’ll need to submit the following information
as well:
o Proof that your effluent system is optimized. The DNR has developed a worksheet
for determining whether your system is optimized and outlining how you plan on
achieving optimization. The worksheet is available online
athttp://dnr.wi.gov/topic/SurfaceWater/documents/POptApproval_%2053112.pdf
(Title: Phosphorus Operational Evaluation & Optimization Report Worksheet).

17 Wis. Adm. Code NR § 217.13(3), https://docs.legis.wisconsin.gov/code/admin_code/nr/217/III/13 .

 o Water monitoring data that demonstrates that your limit is not attainable with your
current system
o A written statement verifying that filtration or equivalent technology will be
necessary to achieve your upcoming limit

The main purpose of this information is to show that facility upgrades alone won’t be sufficient to
meet water quality standards, or that the facility upgrades necessary to meet standards will be
prohibitively expensive.

4-6: Evaluate Your Watershed for the AMO

The steps above are mainly related to determining facility-level eligibility for the AMO. Information
about your facility and its receiving water is important because it’s specifically required for an AMO
permit. However, there are watershed-level factors that aren’t required, yet are highly
recommended as criteria for choosing the AMO. The success of an AMO plan depends not only on
quantitative water quality data, but also qualitative watershed data.
Watershed factors in choosing the AMO include the following:

 Prevalence of agriculture. Agricultural landowner partners will be vital to the success of an

AMO plan.
 Availability and capacity of local conservation experts. AMO implementation will be much
more feasible if your county conservation department, NRCS regional office or other
conservation agency has the staff and resources to assist with your plan.
 Relationships between local stakeholders. Collaboration is a major part of the AMO. Existing
partnerships between local governments, utilities, conservation agencies and the farming
community can be a strong basis for AMO planning and implementation.
 Existence of current watershed plans, TMDLs, urban stormwater management programs or
other runoff management strategies. Such existing data and programs can give you a head
start in data gathering and planning for the AMO. Existing regulatory drivers like TMDLs
can also provide additional incentive for participation.
 Presence of other point sources willing to participate in the plan. Partner facilities can help
make a more significant improvement to water quality, which could relax the effluent limit
assigned to each individual facility. Additionally, other point sources can share funding and
resources.

Although your watershed doesn’t need to include all of these factors for AMO implementation, these
criteria can influence the success of an AMO plan. Ultimately, choosing the AMO will be the result of
facility and cost analyses and discussions with local government, conservation department staff and
other affected stakeholders. If your facility meets all or most of the criteria in this chapter, however,
you meet the basic requirements for the AMO and you can use this information as a starting point
for your discussions about which phosphorus reduction strategy is best for your facility.
Chapter 5: Phase 1 - Gather Data and Build
Partnerships
Successful implementation of the AMO will rely on sound science and strong partnerships. In the
first stage of developing an AMO plan, you’ll focus on gathering and organizing scientific data and
building relationships with stakeholders. This chapter breaks down these steps and provides
resources for obtaining data and creating partnerships.

In this section:
5-1: Determine What Information You Need
An overview of the information needed to develop an AMO plan
5-2: Assess Your Watershed and Determine the Action Area
Tools for gathering data about your watershed
5-3: Build Partnerships with Stakeholders
Strategies for finding partners to play key roles in your AMO
plan.

5-1: Determine What Information You Need

To determine the phosphorus reductions needed in your watershed and to develop an AMO plan,
you’ll need several measurements of water quality and effluent levels. The following sections
describe the measurements needed for an AMO request form and how to obtain those
measurements.

Information Required for the AMO

The AMO request form requires certain information about your facility, your watershed and the
methods you plan on using to reduce phosphorus pollution. The table below summarizes required
information and explains where you can find that information. This handbook goes into greater
detail about each type of information, but you can use this list as an outline during the data
gathering process.

Required Information for AMO Where to Find It

The proportion of P in your watershed from
nonpoint sources
Your facility’s WQBEL
Your facility’s influent and effluent P levels
Your facility’s operational capacity
Watershed
Percent of P that your facility contributes to
overall P in watershed
PRESTO analysis (DNR), TMDL (if applicable),
other models
Provided by DNR during permit renewal process
or self-calculated
Facility monitoring data
Facility monitoring data, facility studies, DNR
facility optimization worksheet
DNR or U.S. EPA watershed locator tools
Calculated with other gathered data
(see Appendix A) or taken from an existing
 TMDL
Action area for the AMO plan GIS maps, county conservation departments,
TMDL and talking to stakeholders
Description of the watershed DNR watershed summaries, county land and
water conservation departments, stream
monitoring data, the USGS, GIS programs, U.S.
EPA
The actions you plan to take to meet water Decided after data analysis (for a summary of
quality limits some possible actions, see section 6-2:
Determine Where and How to Reduce
Phosphorus in Your Watershed)
Specific goals and ways to measure their Decided after data analysis
progress
Partners This handbook (see Appendix B) and elsewhere
Funding sources This handbook (see Appendix C) and elsewhere

Before You Begin

If you measure your facility’s effluent phosphorus under the terms of your current WPDES permit,
you already have a head start in data gathering. The AMO request form includes a section for
describing the current phosphorus output of your facility. You can use phosphorus data you’ve
collected under your current permit to fill out that section of the AMO request form.

Also, if the affected water body already has a U.S. EPA-approved TMDL or there is a watershed plan
for your area, the percent contribution of various phosphorus sources has possibly already been
determined.18 This information can help determine whether nonpoint sources contribute enough
phosphorus contamination for you to qualify for the AMO.

For Wisconsin water bodies with an approved TMDL, go

to http://dnr.wi.gov/topic/impairedwaters/approved_tmdls.html (Title: Approved TMDL Waters).
For a list of watershed plans active as of 2011, go
to http://dnr.wi.gov/topic/SurfaceWater/planning.html (Title: Wisconsin Water Planning).

5-2: Assess Your Watershed and Determine the Action Area

An important early step in developing an AMO plan is determining the affected water bodies in your
area and the sources of phosphorus contamination in those water bodies. You’ll also collect
information about environmental and cultural aspects of the watershed to help inform your actions.
For the plan, you’ll define an action area that encompasses the sources of phosphorus and planned
management measures.

What is my Watershed?

18 Guidance for Implementing Wisconsin's Phosphorus Water Quality Standards for Point Source Discharges , page
107
There are many available sources of watershed data. When you create an AMO plan, the selected
management measures will depend on factors such as the topography, land use, economy and
cultural activities in your watershed. Gathering watershed data should be the first step in your
planning process because it will help you identify potential partners, current threats to the
watershed and existing watershed management plans in the area.

If you’re not sure what your watershed is, you can use the DNR’s watershed search tool
at http://dnr.wi.gov/water/watershedSearch.aspx (Title: Wisconsin Watershed Search). Enter the
name of your facility’s receiving water in the Enter Water Name or WBIC search field. To narrow
your search results, also select your county from the dropdown menu. If there are multiple search
results, you can click the link in the Watershed Code column (for example, LW17) to view a map of
the watershed and confirm that it’s your watershed.

When you’ve found your watershed, click the watershed name to view several categories of
watershed information, including natural features, water bodies in the watershed and their
impaired status, existing grants and monitoring projects in the watershed and future
recommendations for management. You can also view data for individual water bodies within the
watershed on the Water Condition tab. The watershed and water body data will be a good starting
point for your research, and you might be able to incorporate some of this information into your
watershed description in the AMO request form.

You can also use the U.S. EPA’s Surf Your Watershed feature
at http://cfpub.epa.gov/surf/locate/index.cfm (Title: Surf Your Watershed), which you can browse
by several location identifiers such as zip code or city name. This search feature returns a report
that includes links to several types of watershed information, including stream monitoring data,
citizen monitoring groups at work in the watershed and the congressional districts associated with
the watershed. However, be aware that the Surf Your Watershed feature identifies larger
watersheds than the DNR’s watershed search does -- the U.S. EPA divides Wisconsin into 55
watersheds, while the DNR counts 330. The U.S. EPA information can still be useful but might not be
as locale-specific as the DNR’s.

For very extensive, technical information, you can consult NRCS Field Office Technical Guides
(FOTGs), which are collections of county-by-county environmental and demographic data. For a
given area, FOTGs contain information like soil and bedrock type, climate data, area endangered
species, the costs of various agricultural practices, relevant environmental legislation, hydrology
and area maps. These guides are available online to the general public, so you could use these
guides as part of your research. Field guides for Wisconsin are available
at http://efotg.sc.egov.usda.gov/efotg_locator.aspx?map=US (Title: FOTG County Locator).

These are just a few features that you can use to identify and describe your watershed. Although
good starting points for your research, some watershed data might be incomplete or outdated. If
your watershed is missing complete or current phosphorus data, you may use data from similar
water bodies or collect new data.19

No matter how you gather information about your watershed, you should have enough data to
create a broad description about the environmental and social forces at work in your watershed.
Not only will this data help you identify issues and determine how to address them, but it’s also an

19Guidance for Implementing Wisconsin's Phosphorus Water Quality Standards for Point Source Discharges, page
21
administrative requirement – the request form for the AMO requests a description of the
watershed. This description is important because it provides context for the AMO plan and justifies
the actions you select to address issues.

The table below provides a general outline of the types of information that can be helpful in
developing a watershed management plan:

Data Example
Physical and natural characteristics of the Soil type, hydrology (surface water
watershed characteristics), topography, climate
Land use Proportion of agricultural, urban, public and
other types of land, types of agriculture
practices, projected changes in land use
Demographics Population of area municipalities, major
industries, popular activities (e.g., fishing or
boating)
Water bodies and their conditions All water bodies in the action area and their
designated uses and conditions, any Outstanding
or Exceptional Resources Waters, impaired
waters and the reasons for their impairments
Sources of pollution Location and type of point source dischargers
and urban stormwater runoff points. Proportion
of nonpoint and point source phosphorus
contributions.
Water monitoring data Current or planned water monitoring stations,
organizations conducting monitoring,
approximate phosphorus levels in affected
water bodies
Existing efforts to restore or improve water Watershed plans or TMDLs, current
quality in the watershed recommendations, watershed association
projects

Identify the Action Area

While watershed data will be useful in understanding the natural and cultural characteristics of
your watershed, the watershed itself might not be synonymous with the action area for your AMO
plan. The action area might make up a portion of your officially designated watershed, or it might
overlap between two or more watersheds. Ultimately, the action area for the AMO will depend on
the sources of pollution in your facility’s receiving water and the locations of partner point sources
and BMP implementations.

To address phosphorus pollution specifically in your facility’s receiving water, you’ll work primarily
with upstream point and nonpoint sources of phosphorus. Potential partners include farmers,
POTWs and industries that discharge into your facility’s receiving water or its tributaries. Your
county land and water conservation department can determine probable sources of phosphorus
runoff in your watershed.
However, depending on the scale of your plan, you could also work with downstream sources of
phosphorus. For a group of permittees working together, for example, a downstream point source
of phosphorus might want to work with your facility not only to reduce upstream phosphorus for
its receiving water, but also to share resources for planning and implementation. The delineation of
an action area depends not only on the movement of water through the watershed, but on locations
of partner facilities and targeted lands as well. You should submit your proposed action area with
the preliminary AMO request form so the DNR can approve the action area.

You can use the U.S. EPA Nitrogen and Phosphorus Pollution Data Access Tool to locate water
monitoring stations, potential sources of phosphorus discharge, waters impaired due to
phosphorus and land use cover across the region. This tool can aid in determining where to focus
your efforts. For example, follow the steps below to determine the impaired waters in your
watershed and the possible reasons for their impairments:

1. Go to
http://water.epa.gov/scitech/swguidance/standards/criteria/nutrients/npdat_index.cfm
and click Data Access Tool.
2. In the search box at the top of the screen, make sure the Address or Location identifier is
selected and enter your address or zip code. The map will focus on that area.
3. In the Map Layers window, click Waters Listed for N/P Impairments. Water bodies
considered impaired due to high nitrogen or phosphorus levels will appear in red.
4. Click Facilities Likely to Discharge N/P to Water. Triangle icons will appear for facilities
with NPDES permits. You can use this information to determine additional potential point
source partners.
5. Select either or both of the Water Quality Monitoring Sites with N/P options to view current
water monitoring sites through the U.S. EPA or USGS.
6. Select the National Land Cover Dataset option to view the main types of land use in the area
– residential, commercial, pasture, forest, row crops, etc. This information can give you an
idea of the type of pollution contributing to the impairment.
7. Click features on the map to view additional details about that feature. For example, click a
facility likely to discharge N/P to water to view information about its permit and
monitoring requirements, if any.

The screen shot below shows one possible use of the data access tool. The Waters Listed for N/P
Impairments layer is selected, as well as the Facilities Likely to Discharge N/P to Water layer. The
impaired waterway is highlighted in red, and nutrient-discharging facilities appear as pink
triangles.
Choosing the Scale

Just as geographical watersheds can have varied sizes and boundaries, so too can your potential
action areas. Your action area might cover all or most of an officially recognized watershed or it
might cover a smaller sub-watershed. The scale depends on the scope of phosphorus pollution, the
availability of resources and the goals for your AMO plan.

Different sizes of action areas come with scale-dependent pros and cons. A smaller action area has
fewer variables and results may be easier to monitor, but a smaller area also has fewer potential
partners and a smaller potential effect on water quality. Meanwhile, a larger project has the
potential for a greater impact on water quality (and the associated benefits), but greater complexity
and more potential for conflict between stakeholders. The ideal action area will be large enough to
make a significant impact on water quality, but small enough that necessary management actions
are achievable and within your resources.

Submitting a Map

You should submit a map of your proposed action area with your preliminary AMO request form so
the DNR can evaluate the action area early on. The map should include the relevant water bodies
and phosphorus contributors in your AMO plan. Include your facility and other involved point
sources of phosphorus.

Note that while the DNR requests a map of the action area, the map should not be so specific as to
locate specific farms or other rural lands where BMPs will be implemented. You need only to
demonstrate the scale of the action area so the DNR can verify that it’s an appropriate size to
achieve the necessary phosphorus reductions. Although you will work with specific locations to
implement phosphorus management practices as part of your plan, this information is not
necessary in the public AMO plan made part of your facility’s permit.
Your action area map might look something like the map below, which delineates the action area
for the Yahara Lakes pilot project.

(Image Source:
http://www.madsewer.org/YaharaWINs/Resources/YaharaAdaptiveManagementPilotArea.jpg)

Action Area Examples

The table below lists two initial adaptive management pilot projects and the watersheds where
they are taking place, as well as the rationale for selecting those areas for the projects. Although
each watershed is different and the characteristics of one watershed might not translate to another,
AMO project planners may want to consider these rationales when selecting an area for project
implementation.

Project, Watershed Rationale

Yahara WINS, Six Mile Creek Watershed
 Located within MMSD's Yahara River
watershed
 Contains previously installed USGS water
monitoring stations
 Has an established citizen monitoring
program for the area and abundant water
quality data

NEW Water, Silver Creek Watershed
 Located within NEW Water's Lower Fox
River Basin
 Contains a previously installed USGS water
monitoring station
 Several years of water quality data
 Potential to return stream to historical trout
stream quality
 Majority landowner is Oneida Tribe,
providing additional control over
conservation practice implementation
 Small area (7.5 square miles) allows for
manageable implementation

Resources for Gathering Water and Watershed Data

Several organizations run water quality monitoring programs and provide water quality data
online. The DNR’s SWDV was described earlier in this handbook as a tool for determining a
phosphorus exceedance, and it can also be used to gather other water quality information. This
section describes some other data repositories you can use to gather information about water
quality in your watershed.

National Water Information System (NWIS)

The U.S. Geological Survey (USGS) maintains water monitoring stations across Wisconsin and the
nation. If there is a site for your receiving water that’s reasonably close to your facility, you could
use this monitoring data to establish initial phosphorus levels in the water body. The USGS water
quality database is relatively straightforward to use, so this step in data gathering can be performed
by staff at your facility.

The home page for USGS water quality data in Wisconsin is

at http://wi.water.usgs.gov/data/waterquality.html (Title: Wisconsin water-quality data). From
this page, you can access databases of real-time water monitoring data and view summaries of
water quality information over time.
The USGS maintains water monitoring information in a database called the National Water
Information System (NWIS). This database is available through the link above but can also be found
through other water quality information systems, such as the U.S. EPA tools explained below.

STORage and RETtrieval database (STORET)

The U.S. EPA also stores water monitoring data in a database available to the public. The STORage
and RETrieval database (STORET), like NWIS, contains nitrogen and phosphorus data from many
monitoring sites across the country. STORET data is incorporated into the Surf Your Watershed
feature and will appear as a link with the watershed description.

To directly access STORET data for your area, go

to http://www.epa.gov/storet/wtshd_summary.html (Title: STORET Warehouse Watershed
Summary) and type your zip code into the search box. Then, select your watershed from the search
results. The search will link to the same watershed report that appears through the Surf Your
Watershed feature. Click the “Water quality monitoring data from this watershed” link to view
STORET information.

In the screen shot below, a red box appears around the link to STORET data.

Information from these databases, if available, current and complete, can supply the background
phosphorus concentration for your plan. However, be sure to check the date and location of
gathered data. For example, in the NWIS database, phosphorus stream data might be several years
out of date, depending on the site of the gauge. Accurate modeling predictions of water quality data
depends on accurate data inputs, so you should not use measurements more than a few years old.
According to the DNR, data more than five years old might not count when determining a
phosphorus exceedance.20

5-3: Build Partnerships with Stakeholders

The success of an AMO plan depends on close collaboration between stakeholders. No matter the
size of a permittee’s facility or organization, there will be areas where the permittee will need
assistance, whether in gathering data, developing a plan, obtaining funding or monitoring water
quality.

You can find partners at the local, state and federal levels. We recommend that you start building
partnerships on the local level, because local partners will likely have more background and vested
interest in your project’s action area.

For a list of potential partners, descriptions of the roles they can play and contact information, go
to Appendix B: Potential Partners.

Identify a Facilitator

One of the first steps in building partnerships should be identifying a facilitator, who will be
responsible for planning and implementing on-the-ground phosphorus reduction practices. This
role can be performed by one person or by a group. In many cases, this role will be played by the
county conservation department. In the Yahara Lakes pilot project, for example, the Dane County
Land and Water Resources department acts as a facilitator to identify specific phosphorus
reduction projects, guide their implementation and track their progress. The facilitator may also act
as a liaison between many different groups and generate discussion between different interests.

The facilitator will be responsible for working with farmers, landowners, and municipal engineers
to reach agreements that result in the installation of on-the-ground practices to reduce phosphorus
runoff. As such, the facilitator is a critical partner to your success. Take time to build a good rapport
and a strong relationship with open lines of communication and trust before selecting your
facilitator. The facilitator will also require funding, so take this cost into account when estimating
costs for your plan.

The facilitator will be particularly helpful in identifying potential farmer partners and initially
approaching them to participate in the plan. Rather than directly contacting individual farmers at
the outset of your plan, work with your facilitator to determine how to prioritize lands based on
environmental need and the willingness of the landowner to participate. Your facilitator can then
approach farmers with options for reducing phosphorus output though management.

The following are a few criteria you can consider when selecting a facilitator:

 Familiarity with land use in the watershed and the major sources of point and nonpoint
phosphorus pollution
 Established relationships with local farmers and landowners
 Understanding of phosphorus-reducing BMPs and their application in your watershed

20 Guidance for Implementing Wisconsin’s Phosphorus Water Quality Standards for Point Source Discharges , page
89
  Capacity for water quality modeling
 Knowledge of state and federal funding programs
 Experience with project management

Determine Farmer Leaders

Strong farmer participation will be crucial to a successful AMO plan. To help increase participation,
identify experienced local farmers who can provide recommendations for the plan and leadership
for other farmers. (Your facilitator may identify individual farmers.) These farmers can suggest best
management practices based on existing farming practices in the watershed, identify potential
issues or barriers, recommend strategies for farmer outreach and educate other farmers about the
AMO.

Not only can farmer leaders aid in outreach and education, they can also build credibility for the
plan and bridge the gap between farmers and non-farmers. According to a study of conservation
practice adoption in agricultural watersheds, farmers were more likely to implement conservation
practices if the practices were explained and promoted by a trusted, respected agricultural leader.21

For example, a key group in the Yahara AMO pilot project is a group of farmers who call themselves
Yahara Pride. Go to http://www.yaharapridefarms.org for information about this group.
Meanwhile, in the Lower Fox River Basin, a project is underway to showcase conservation practices
on selected farms. This project, called the Demonstration Farms Network, is a joint effort between
the Great Lakes Commission, NRCS and Brown County conservation department. The purpose of
this project is to highlight technologies and practices that reduce phosphorus, as well as their costs
and impact on crop yields.

Inventory Stakeholder Skills

At your stakeholder meetings, it will be beneficial to take inventory of the types of skills that
partners bring to the table. It can be less expensive and more efficient to use existing staff,
stakeholders or volunteers to perform various aspects of your plan than to outsource to a
consultant or other external entity. In your initial meetings, survey the group for their experience in
skills in areas that relate to your plan. For example, the following types of skills could benefit your
project:

 GIS
 Watershed science/research
 Outreach/strategic communication
 Graphic/web design
 Media involvement
 Project management
 Fundraising
 Meeting facilitation
 Legal counsel

21Jennings, G. D., D. Hoag, M. L. McFarland, and D. L. Osmond. “Lessons Learned from the NIFA-CEAP: Effective
Education to Promote Conservation Practice Adoption,” (NC State University, Raleigh, NC,
2012). http://www.soil.ncsu.edu/publications/NIFACEAP/Factsheet_4.pdf
  Grant proposal writing

Tips for Building Partnerships

 Make connections with potential partners as early as possible in the planning process.
Partners are integral to the AMO and can bring in expertise, staffing and funding that can
advance your plan and build its credibility.
 Focus on the benefits of the AMO specific to the partners you approach. For example, you
might focus on the financial benefits for a potential partner municipality, while you might
focus on water quality and property value improvements for a lake association.
 Use positive language to describe the plan to current or potential partners. For example,
focus on verifying results rather than enforcing water quality standards.
 Demonstrate solid scientific and economic reasoning for partners to sign on to the AMO. For
partners who are wary about signing on to an AMO plan, a strong demonstration of
economic benefits can help build willingness to collaborate.
 Keep partners actively involved through regular meetings and open communication.
Newsletters and websites are good ways to help make sure that all involved partners are up
to date on the project’s status.
 Obtain written commitments or contracts from partners to help ensure continued
collaboration. When you submit your request form for the AMO, the DNR requests copies of
any contracts between you and non-agricultural partners in the plan. (See the section below
for additional information about agreements with partners.)

As a real-world example, MMSD used cost-effectiveness as a major message to gain municipal

partners in the Yahara pilot project. Since almost all of the municipalities in the Yahara watershed
are customers of MMSD, their water rates will reflect the cost of MMSD's compliance option, so it's
in their interest to support the AMO as a more cost-effective option. However, despite the potential
economic benefits of the AMO, it's a relatively unfamiliar option, and some Yahara partners
required numerous conversations with MMSD before deciding to participate in the project.
Therefore, be prepared to allocate adequate time for acquiring partnerships.

Establish Binding Agreements with Partners

To help ensure continued commitment from partner individuals or organizations, it’s highly
recommended to create a contract or memorandum of understanding (MOU) with stakeholders
involved in your AMO plan. Your agreement may or may not be legally binding, depending on the
level of commitment partners are willing to demonstrate. Whatever route you choose, the binding
agreement could include the following stipulations:

 The phosphorus reductions for which each facility or organization is responsible

 The monetary contribution expected from each partner
 The tasks each partner has agreed to perform
 Definitions of water quality standards and indicators of completion
 Conditions for breaking the agreement or withdrawing from the plan

The purpose of these agreements is to increase accountability for various partners (increasing the
likelihood that they’ll maintain their commitment) and to reduce ambiguity in the requirements in
the plan and the expectations for each partner. If you establish a binding agreement, submit this
document to the DNR with your AMO request form.

For an example, review the MOU for the Yahara Lakes pilot project as a PDF
here: http://www.madsewer.org/YaharaWINs/Resources/MOU.pdf (Title: Memorandum of
Understanding for an Adaptive Management Pilot Project in the Yahara Watershed).
Chapter 6: Phase 2 - Analyze Data
After you’ve gathered data about the source and type of phosphorus pollution in your watershed,
the next step is to use that data to determine the following information:

 The total phosphorus reduction that needs to occur to meet water quality standards
 The proportion of phosphorus that your facility contributes to the watershed
 The actions you’ll take to accomplish phosphorus reductions and their costs
 The estimated phosphorus reductions due to each action in your plan

Calculating the phosphorus reduction you need to accomplish is relatively straightforward and can
be accomplished by an in-house staff member at your facility. Estimating load reductions due to
nonpoint control actions, meanwhile, requires more data and the use of modeling software, which
will most likely require outside help. This section explains how to calculate load reductions and
gives an overview of estimating and achieving phosphorus load reductions.

In this section:
6-1: Calculate Required Phosphorus Reduction
Quantify the total phosphorus reductions needed to meet water
quality standards and the proportion of the reduction you'll
initially be responsible for.
6-2: Determine Where and How to Reduce Phosphorus in Your
Watershed
Identify watershed-wide or site-specific phosphorus reduction
measures and use models to estimate the effectiveness of the
measures.
6-3: Determine How Actions Will Be Funded
Explore grants and cost-sharing programs that will fund
phosphorus reduction practices.trategies for finding partners to
play key roles in your AMO plan.

6-1: Calculate Required Phosphorus Reduction

To quantify goals for the AMO plan, you will calculate both your facility’s phosphorus output and
the total phosphorus reductions needed across the watershed to achieve water quality standards.
Although required reductions may change between permit terms based on changes to water
quality, calculating the necessary load reductions during the planning process will help develop
initial goals and strategies for achieving them.

The proportion of phosphorus that your facility contributes to overall phosphorus pollution in the
watershed determines the approximate amount of phosphorus that you will initially plan to offset.
For example, if your facility contributes 10 percent of the phosphorus in your watershed, you’ll
initially be responsible for implementing practices that achieve 10 percent of the necessary
phosphorus load reductions across the watershed. If you’re working with multiple point source
facilities in your watershed, the proportion of phosphorus that each facility contributes to the
overall baseline can be a factor in determining a given facility’s monetary and staff contribution to
AMO implementation. For example, under the Yahara pilot project MOU, point sources are expected
to contribute a share of project costs in proportion to the percentage of phosphorus each
contributes to the watershed, as outlined in the Rock River TMDL report.

However, keep in mind that the AMO is centered on achieving water quality standards. If the initial
calculated offset is achieved, but phosphorus levels in the receiving water are still above the
established standard, you will need to take additional measures to reduce phosphorus. According to
the DNR, you won’t be responsible for more phosphorus reductions than your facility’s
proportional share during the first permit term under the AMO.22 During this term, we recommend
setting a phosphorus reduction goal over the required amount for your facility as a precautionary
measure to help ensure meeting future effluent limit requirements.

On the request form for the AMO, you are required to enter the percent contribution of your
facility’s discharge to the overall phosphorus pollution in the watershed. The worksheet
in Appendix A can help you determine your facility’s percent contribution of phosphorus to the
receiving water and the approximate load reduction for which you’re initially responsible.

Note: If there is an existing TMDL for your area, the TMDL report might already include the
different sources of phosphorus pollution in the area and the proportional loads of each source.
(The Wisconsin water bodies with U.S. EPA-approved are available at
http://dnr.wi.gov/topic/impairedwaters/approved_tmdls.html.) If the TMDL report outlines your
proportional share of phosphorus loading, you can use this information in your AMO request form.

6-2: Determine Where and How to Reduce Phosphorus in Your

Watershed

Once you’ve calculated or obtained the load reductions necessary in your action area, the next step
is to determine how you’ll achieve those reductions. Your plan can include both point source
controls, like facility upgrades and optimization, and rural and urban nonpoint source controls.
Achieving phosphorus reductions will require identifying and analyzing major sources of runoff in
the action area and selecting appropriate runoff management practices for those sources.

Because these steps will require significant knowledge of local agriculture and areas at a high risk
for phosphorus runoff, plan partners with expertise in these areas will play a major role. This
partner could be your facilitator or another expert, such as a local UW extension agent, NRCS
scientist or agronomist. For simplicity, this section refers to this expert as your facilitator.

Identify Vulnerable Lands

The first specific sites your AMO plan should target are vulnerable lands, or those with a relatively
high risk for phosphorus runoff. In general, to make the greatest impact on water quality, BMPs
should be implemented at the sites with the highest phosphorus contributions.

22 Guidance for Implementing Wisconsin’s Phosphorus Water Quality Standards for Point Source Discharges , page
91
Your facilitator should identify vulnerable lands in the action area. Knowing the major sources of
phosphorus in the area will be crucial to prioritizing management actions. Your facilitator should
use the P Index to identify fields at a high risk for phosphorus runoff and start to determine why
those fields are at risk.

However, keep in in mind that some strategies may have a wider scope than individual high-risk
lands. Your plan could incorporate county-wide ordinances on agricultural practices or additional
BMP implementations on fields at a lower risk of significant phosphorus runoff. Identifying
vulnerable lands is an efficient way to target your efforts, but not the only way

Analyze Root Causes of Pollution

Before considering BMPs for vulnerable lands, it’s important to determine why the lands are
vulnerable for runoff. Identifying the root cause of runoff on a given site can help you develop more
effective solutions.

Consider a field that your facilitator identified as a source of significant phosphorus loading.
Interviews or surveys of landowners about their land management practices can help pinpoint the
sources of excess phosphorus. Are cows allowed to enter streams? Is manure applied on frozen
ground? Is there a nutrient management plan in place for the field? Does the landowner till all or
the majority of the cropland? Once the root cause is determined, your facilitator can take steps to
improve phosphorus management, such as educating the landowner about the benefits of no-till
agriculture or assisting the landowner with developing or updating a nutrient management plan.

Encouraging a change in practices can involve education, marking or enforcement actions. For
information about promoting changes in management practices, go to the Outreach Strategies
section in Chapter 7.

Evaluate and Prioritize Runoff Control Options

There is a wide variety of best management practices (BMPs) for controlling rural and urban
nonpoint source phosphorus pollution. Depending on the source and root cause of nonpoint source
pollution in your action area and the resources available for BMP implementation, some BMPs will
be more cost-effective or realistic than others.

Selecting BMPs will depend on factors like the willingness of landowners to participate, the
phosphorus reductions projected to occur due to each BMP and their net costs. This section goes
over the general process for evaluating and selecting the phosphorus-reducing actions to
incorporate into your plan.

Obtain Agreements with Landowners and Municipalities to Implement BMPs

Farmers and other landowners will typically have the final say in which practices, if any, will be
implemented on their lands, so working with area landowners will be the first step in narrowing
down possible BMPs to implement. Once landowners have expressed interest in participating in the
plan, your facilitator can work with them to determine which BMPs will be feasible and appropriate
for the identified vulnerable lands.
Discussions about which rural BMPs to implement will generally take place between farmers and
your facilitator or other farmer liaison. However, there may be some situations where you and your
stakeholder group or municipal partners can have a say in which rural BMPs to implement as a part
of the plan. For example:

 Purchasing conservation easements, which are the usage rights to a given plot of land. Local
governments or land trusts working with you can purchase conservation easements on
vulnerable land with the agreement of the landowner. In this situation, the landowner still
owns the land, but must manage it as specified by the purchaser of the easement. The Town
of Dunn in Dane County, for example, has a Land Trust Commission that oversees the
purchase of land for conservation purposes.23
 Establishing ordinances. If you have partners in municipal or county government, these
partners may be able to work toward establishing local land management standards. For
example, Brown County, WI has an ordinance that requires 35-foot vegetative buffers on
stream bank in the county’s unincorporated municipalities.24
 Pursuing specific BMP initiatives. If resources allow, your stakeholder group may be able to
coordinate on larger-scale projects. For example, in Dane County, WI, the county has
invested in manure digesters to remove phosphorus from manure from several farms
before the waste is applied to fields. The digester projects have involved collaboration
between state and local government, private industry and multiple farmers whose farms’
waste is treated by the digester.

Although operators at point source facilities are not expected to be directly responsible for working
with landowners to select rural BMPs, you may want to familiarize yourself with common BMPs
and their associated considerations for a starting point in planning. For an overview of rural and
urban phosphorus-reducing BMPs, go to Appendix D.

Model Projected Load Reductions

Once you’ve quantified the load reductions for which your facility is responsible and your facilitator
has identified potential BMPs and their locations, the next step is to predict how the identified
BMPs will achieve the required load reductions. Solidly demonstrating how the chosen BMPs will
reduce phosphorus loading is necessary for two reasons: to fulfill the requirements for the AMO
and to estimate the cost of the AMO plan.

Estimating the load reductions that will result from BMP implementations can be complex. You can
find studies online or in journals that demonstrate load reductions based on specific BMP
implementations, but values from literature will vary greatly since they’re so dependent on the
local conditions of the study. A more targeted way of estimating phosphorus load reductions is
using runoff modeling programs.

23“Land Trust Commission,” Town of Dunn,

2012, http://town.dunn.wi.us/townofdunn/government/land+trust+commission+agendas/default.asp .
24“Agricultural Shoreland Management Ordinance,” Brown County, WI,
2012, http://www.co.brown.wi.us/departments/page_b5e40bb5a619/?department=097c0e79486a&subdepartment=7c
17181709a3.
There are several models available to determine approximately how much phosphorus reduction
will occur due to a given BMP. For example, the following programs can be useful in developing
your plan:

 SNAP-Plus: A Wisconsin model for estimating farm-specific effects of BMPs through the use
of the P Index in a nutrient management plan. Available at http://www.snapplus.net.
 SWAT: A model for estimating, among other things, the effect of agricultural practices
(including BMPs) in a given watershed. Available athttp://swat.tamu.edu.

Using modeling software to estimate load reductions will likely be beyond the scope of many
facilities. Models vary widely in the time, training and software necessary to run them effectively.
Unless staff members at your facility or partners in your AMO plan have experience using runoff
modeling programs, you should consult with experts to obtain model load reduction estimations.

The following sources may help you with modeling phosphorus load reductions:

 Your county conservation department or local USGS office

 Research staff at local colleges or universities
 Environmental consultants. If you’re planning on hiring a consultant to develop your plan,
make sure that they have experience using runoff modeling programs.

Although potentially resource-intensive, modeling with complete, current data can help you better
estimate the cost, necessary labor and potential effectiveness of various BMPs. Accurate modeling
will also increase the credibility of your plan for potential partners and funding sources. If you have
any questions about the appropriateness of the models or data inputs you’re using, contact DNR
modeling staff. The DNR Adaptive Management Technical Handbook includes a table that lists and
compares various modeling tools for estimating phosphorus load reductions (page 63).

Estimate Costs and Compare BMP Effectiveness

An integral part of selecting a BMP will be determining its net cost. After modeling the projected
phosphorus load reductions associated with a given BMP, work with your facilitator to estimate the
cost associated with that BMP to further determine its feasibility.

A good way to compare various BMPs is to calculate the cost per unit of phosphorus load reduction.
For example, the environmental consulting firm Kieser & Associates used SWAT modeling to
determine the relative effectiveness of five agricultural BMPs in a Michigan watershed. Their model
determined that when implemented on 25 percent of available land, filter strips cost $115,000
annually and cover crops cost $98,000 annually. However, because their model showed that filter
strips led to a greater reduction in phosphorus loadings than cover crops, filter strips ended up
costing $2.84 per pound of phosphorus reduced, while cover crops cost $5.35 per pound of
phosphorus reduced.25

This example is not meant to imply that filter strips are always a more cost-effective option than
cover crops or that the cost information is applicable to your watershed – the actual cost and
effectiveness of each option will vary from plan to plan – but illustrates the importance of long-term

25Kieser & Associates, “Modeling of Agricultural BMP Scenarios in the Paw Paw River Watershed using the
Soil and Water Assessment Tool,” February 2008. http://kieser-
associates.com/uploaded/pawpaw_swat_modeling_report_final_v4.pdf .
planning when considering which BMPs to implement. Because the AMO focuses on watershed-
level outcomes, selecting a BMP that is more expensive initially, but more effective, might actually
end up saving money in the long run. If, using the example above, filter strip implementation results
in a significant phosphorus reduction in the receiving water over the permit term, the DNR might
increase the WQBEL for a given facility, relaxing the financial and environmental burden for that
facility.

In addition to projecting costs of BMP implementation and maintenance, your estimate should take
other plan expenses into account, such as staff time, outreach materials and third party
assistance. For example, if the county conservation department is heavily involved in
implementation, the department will likely need a source of funding.

Prioritize Management Actions and Their Locations

The BMPs you select and the lands on which they’re implemented will depend on factors like
landowner cooperation, the cost-effectiveness of the BMP and the resources available for
implementation. Realistically, these factors will likely limit the types of BMPs implemented in your
plan. You will need to prioritize BMPs to ensure that resources are being used effectively.

As a rule, you want to prioritize actions that will have the greatest impact on water quality in your
watershed relative to cost. If a given plot of land is both environmentally vulnerable to runoff
events and it’s being managed improperly, you can achieve a relatively significant impact on water
quality by targeting environmental and management improvement strategies to that land.

The following is a general outline of the prioritization steps for an AMO plan:

1. Identify the major sources of point and nonpoint phosphorus pollution in the watershed.
2. Quantify the approximate amount of phosphorus for which each source is responsible.
3. Identify the top phosphorus contributors based on amount of phosphorus discharged per
year.
4. Identify the root cause of the phosphorus pollution for each of the top sources.
5. Subdivide the top phosphorus sources into priority levels based on factors like the root
cause of pollution, willingness of the landowner to participate, vulnerability of the land to
runoff and available funding for the area.
6. Prioritize the types of actions to implement in the top-priority areas. If time or funding limit
the type or number of BMPs that you can implement at one time, identify the practices that
will be the most practical or cost-effective at the moment and make them a top priority.
7. Expand your efforts to lower-priority lands or goals after top priorities have been
addressed.

Keep in mind that this process is only an outline. Ideally, you will be able to focus your efforts on
the land and landowners with the greatest potential phosphorus reductions, but these targets may
not always be realistic (at least initially). Landowners may be unwilling or unable to participate in
the plan, for example, or the most effective BMPs might be out of the current budget for your
project.

However, prioritization is not all-or-nothing. Any runoff management measures you take, providing
that they are properly planned and implemented, have the potential to reduce phosphorus
pollution and improve water quality. If the best-case actions aren’t feasible at a given time, lower
priorities that have a greater potential to achieve results can become your top priorities in the short
term.

Real-World Examples: Prioritizing BMPs in Pilot Projects

Here's how the AMO pilot projects in the Yahara and Silver Creek watersheds are prioritizing BMP
selection, demonstrating a few factors that can go into the prioritization process.

Yahara

In the Yahara pilot watershed, USGS monitoring data showed that manure was the primary source
of phosphorus in the watershed. Therefore, the main BMPs being implemented in the Yahara
project are designed to reduce manure runoff, including vertical manure injection, buffer strips, and
cover crops. To incentivize additional, innovative low-cost practices, Yahara WINs is also using a
"reverse auction" program that funds projects based on the lowest potential cost per pound of
phosphorus reduced, with the goal of finding the most cost-effective ways to reduce phosphorus.

Silver Creek

One consideration when selecting conservation practices is their longevity -- some agricultural
conservation practices have a limited lifespan and need to be renewed to maintain effectiveness,
while others, such as conservation easements, last longer. NEW Water is particularly interested in
funding perpetual conservation practices to ensure investment in long-term phosphorus
reductions.

6-3: Determine How Actions Will Be Funded

One of the required elements for the AMO is a demonstration that you have sufficient funding
available to achieve your management actions. If you have sufficient funds available, your facility
could be the sole funder for projects under the AMO. However, one of the advantages of the AMO is
that it can provide flexibility in funding sources to help defray your total costs.
There are several funding opportunities available to point sources and farmers to offset the costs of
BMP implementation.

Cost-Sharing

Cost-share agreements are a fundamental part of many agricultural conservation programs. Under
such agreements, a funder agrees to provide all or part of the cost of implementing or maintaining a
conservation practice. For example, an agreement between a funder and a landowner could specify
that the funder reimburse the landowner for 75 percent of the cost of planting a vegetative buffer
strip.

Contracts between your facility or municipality and landowners are the most direct option you
have for funding BMPs. In a basic agreement, after your facilitator has worked with landowners to
determine the BMPs to implement and estimated their cost, you’ll provide landowners with an
agreed-upon portion of the cost.
Such agreements are important not only because they put a specific dollar amount on practices,
helping you estimate total costs, but also because they create a degree of accountability for
landowners. As a funder, you want to have some assurance that the practices you’re funding will be
effective in the long term. Cost-share agreements, therefore, should contain provisions to ensure
proper use of funding.

In an administrative sense, cost-sharing is used in Wisconsin to enforce the runoff management

standards in NR 151. This type of cost-share is administered through county governments or the
DNR. If a landowner is offered cost-share through county government for a given agricultural
practice, the landowner must repay the county all cost-share if the funded practice isn’t maintained
per the terms of the agreement.26

Agricultural Conservation Programs

There are many state and federal programs that provide financial and technical assistance for
agricultural BMP implementation. Because finding external funding for BMP implementation can
reduce your facility’s financial obligations, it’s a good idea to familiarize yourself with programs
available in your watershed. Go to Appendix C: Funding Sources for a partial list of state and federal
programs that you may be able to incorporate into your plan.

For an example of cost-share available to farmers, the Environmental Quality Incentives Program
(EQIP) through the NRCS provides funding and technical assistance for certain BMP
implementations. The Wisconsin NRCS has a guidebook with the eligible types of BMPs and the
amounts for which farmers can be reimbursed for their implementation. The 2012 guidebook is
available as a PDF at the following
link:http://www.wi.nrcs.usda.gov/programs/eqip/eqip12/WI%20EQIP%20cookbook%20FY12.pd
f (Title: List of Eligible Practices and Payment Schedule FY 2012 Wisconsin).

Performance-Based Compensation

The AMO is a unique approach to conservation in that it focuses on achieving specific results, rather
than implementing specific actions. You may want to take this approach when funding your plan.
Rather than compensating farmers only for the specific action of BMP implementation, you could
consider compensating farmers based on the projected or real phosphorus reductions achieved
through those BMPs.

For example, consider a “reverse auction” approach, which compensates farmers for specific
projected phosphorus reductions. In this approach, you would request a specific phosphorus load
reduction from farmers, who can then take whatever measures they see fit to achieve that
reduction. When farmers, with help from conservationists or other agricultural modeling experts,
demonstrate that their chosen practices will achieve the necessary load reductions, you will
reimburse farmers based on the chosen practices. This strategy encourages innovative practices
and shifts some of the responsibility of phosphorus reductions from point sources to farmers – if
they don’t achieve the agreed-upon phosphorus reductions, they aren’t reimbursed.

26 Wis. Adm. Code ATCP §50.40(9)(k), https://docs.legis.wisconsin.gov/code/admin_code/atcp/50/V/40.

A similar approach is to offer a tiered pay-for-performance reimbursement system: the greater the
phosphorus reductions achieved by a landowner, the greater the reimbursement. This system can
level the playing field for producers in compliance and those not in compliance with environmental
standards. For example, simply paying farmers to implement phosphorus-reducing BMPs might
seem unfair to farmers who currently have BMPs in place. Alternatively, paying farmers for a
certain number of pounds of phosphorus reduced, or for achieving or maintaining a certain
phosphorus index in their fields, can incentivize not only BMP implementation, but ongoing
maintenance as well.

Applying for Grants

Some grants may be directly available to your facility, rather than to agricultural operations. If there
is not a stakeholder in your group with experience writing grant proposals, applying for grants
might seem like a daunting task. However, many of the requirements for a successful grant proposal
overlap with the requirements for creating a watershed AMO plan, so you will have a bit of a head
start for grant applications. Many grant applications request details like timelines, budgets,
partners and specific management measures – all information that you should already have for
your AMO plan.

The best way to obtain a grant is to apply for the grant that best aligns with your project. Most grant
descriptions have a specific list of criteria, so carefully read and evaluate different grant
opportunities. Then, tailor your grant proposal to those criteria, explaining exactly how your
project will meet the requirements for the grant.

The U.S. EPA, along with Purdue University, developed a tutorial about writing grant proposals.
This tutorial also includes examples of different types of grant proposals that you can use as a
model. The tutorial is available as a PDF
at http://www.epa.gov/region7/citizens/care/pdf/epa_grant_writing_tutorial.pdf (Title: EPA
Grant-Writing Tutorial).
Chapter 7: Phase 3 - Create the AMO Plan
After you’ve gathered and analyzed data, you'll have a basis to put together your AMO plan.
An AMO plan, as a watershed-level approach to conservation, is essentially a watershed
management plan. Although you aren’t required to develop a comprehensive watershed plan for
the purposes of the AMO, you will still use traditional watershed management strategies in drafting
your plan and permit application. For this reason, this chapter describes watershed planning
processes and recommendations as well as the specific requirements for an AMO plan.

Creating an AMO plan, since it involves a high level of research, modeling and planning, will be
beyond the scope of most individual permittees. This is a step in which strong partnerships with
other stakeholders will be essential. For example, local conservation departments can provide
background data and conservation recommendations, extension agents can recommend outreach
strategies for the farming community, county government can develop ordinances for enforcement
and nonprofit organizations can provide volunteers for water quality monitoring.

Because of the effort involved in creating an AMO plan, this chapter is not intended for one sole
stakeholder. Rather, this chapter outlines the information that should appear in an AMO plan and
provides resources for developing the plan.
The DNR's technical handbook on the AMO extensively covers the required elements of an AMO
plan. While drafting your plan, refer to the technical handbook
at http://dnr.wi.gov/topic/surfacewater/adaptivemanagement.html.

In this section:
7-1: Set Goals, Objectives and Indicators
Determine milestones to measure the success of your plan.
7-2: Develop Core Strategies for Your Plan
Identify ways to increase participation in the plan, organize
participants and verify compliance with best practices and
environmental standards.
7-3: Develop the Implementation Plan
Bring together your gathered data, identified partners, funding
sources and management measures into a plan for submittal to
the DNR.

7-1: Set Goals, Objectives and Indicators

After collecting a diverse data set about the watershed, you’ll be able to identify areas you need to
address in your plan. The most basic goal you’ll set is that required by your permit: achieving the
interim phosphorus limits and, ultimately, the final WQBEL assigned to your facility.

To obtain a discharge permit with an approved AMO provision, your AMO plan is required only to
describe your strategy for achieving required water quality standards. However, this goal does not
have to be the only focus of your plan. Depending on your partnerships, the other environmental or
cultural issues affecting your watershed and available resources, you might want to set additional
goals for your watershed. Other goals that can be part of a comprehensive, long-term watershed
plan could include controlling aquatic invasive species or increasing revenue from tourism and
water recreation.

Incorporating other stakeholders’ goals into the AMO plan can be useful in building partnerships.
The more comprehensive your plan, the more groups are likely to have a vested interest in its
outcomes, and the more resources you’ll have available for planning and implementation. For
example, including a goal of restoring riparian (shoreline) habitat for wildlife could appeal to
sportsmen’s groups like Ducks Unlimited. In turn, these groups could provide staff resources,
collaboration on project implementation and other valuable assets. In your stakeholder meetings,
review the gathered data and ask plan partners what they view as their biggest concerns in your
watershed. However, still focus primarily on the goal of adaptive management: attaining required
phosphorus levels in the receiving water.

Whatever the overall vision is for your watershed, the plan you create can be broken down into
goals, objectives and indicators:

Goals are broad, long-term visions for the watershed. Goals describe what you want to accomplish
with your plan. For example, your plan might state a goal of “Improve water quality by reducing
nonpoint phosphorus pollution.” Depending on the resources available and the scope of your plan,
you may have additional watershed goals beyond meeting water quality standards.

Each goal will have a set of objectives that describe how your plan will meet that goal. The above
goal of reducing nonpoint phosphorus pollution might include the following objectives:

 Achieve a certain percent phosphorus reduction on agricultural lands while maintaining or

improving farm profitability
 Prevent or reduce the frequency of beach or lake closings due to algal blooms
 Develop outreach and education plan to encourage BMP adoption

Since plans will vary across watersheds, the objectives you set will likely be more specific than
these examples. Your plan should include the specific BMPs you plan on implementing, the reasons
they were selected and the load reductions they’re projected to cause based on modeling. As a part
the permit application for the AMO, the DNR requires you to identify where load reductions will
occur and to describe the management measures you’ll implement to accomplish those reductions.
Although you do not need to be as specific as identifying individual landowners (in fact, the DNR
discourages this), you should provide justification for how you chose your management objectives.
For example, explain that you chose areas with higher P indices and BMPs with a relatively high
modeled cost-effectiveness for your management measures.

Last, each quantifiable objective should have measurable indicators to prove that it’s being
accomplished. The indicator for meeting your facility’s effluent limit, for example, is the phosphorus
level in the effluent. Other indicators to measure progress include the P Index for vulnerable lands
and the phosphorus levels in receiving water and across the watershed.

In addition to high-level, long-term goals, you will also set an implementation schedule with interim
milestones to show progress toward your end goal. Because of the variable nature of nonpoint
pollution, it’s a good idea to give yourself extra time in your permit term to achieve your effluent
limits. For example, setting a goal to meet your interim phosphorus limit by year 3 of your permit
term gives you two years to plan and model appropriate adaptations for the next permit term. You
should also consider setting phosphorus load reduction goals over the minimum required amount
as a safety measure to account for uncertainty in projected phosphorus reductions.

7-2: Develop Core Strategies for Your Plan

For your plan to be successful, you need to develop strategies to ensure that the desired results are
accomplished. While setting goals to meet water quality standards is largely based on scientific,
quantifiable data, developing strategies will incorporate more of the social, economic or cultural
aspects of your watershed.

Outreach Strategies

Because the AMO is a new approach to conservation, educating farmers and other stakeholders
about the process is key to ensuring participation. Education materials, meetings and direct
interaction can explain the economic and environmental benefits of the AMO for stakeholders. This
section explains how to target your message to change behavior and ways of getting those
messages across.

If developing an outreach campaign is beyond the scope of your facility, work with partners with
experience in information and education. For example, staff at UW Cooperative Extension or your
county conservation department may be able to help with outreach strategy and materials. You
might find this section useful if you’re involved in developing an outreach plan. If not, you can skip
or skim this section.

Drivers of Behavior Change

Different people respond to different messages. Some producers you work with will respond to a
message of conservation and protecting water quality, some will respond to financial incentive and
some will respond to the possibility of fines or penalties. The messages you choose can fall within
three main categories: education, marketing and enforcement. Before deciding which message to
use, however, you need to understand your audience and their motivations. Understanding the
reason for a behavior is the first step in encouraging behavior change.

Know Your Audience

The more targeted outreach is, the more likely it is to be effective. Before developing outreach
materials, identify the farmers in your watershed and those who work with farmers, such as county
conservationists, UW Extension educators and USDA farm service agents. Along with your
stakeholder group, try to build direct relationships with as many producers as you can -- invite
them to planning meetings, arrange site visits of farms and find out any concerns farmers might
have about their part in the AMO. Your facilitator should ask them about current farming practices
and goals that they have for their farms. This information can help you determine the type of
message to develop for the target audience.

It’s not only the type of message to target, but who to target as well. In any campaign to change
behavior, some members of the audience are more eager and able to adopt behavior change than
others. For example, a farmer who has been considering a transition from confined feeding to
grazing might be relatively easy to persuade to fully adopt this conservation practice as a part of an
AMO plan. This group, called early adopters, will likely respond to a different message than those
who are less willing to change. This group can also help persuade other producers to try BMPs
themselves.

Your facilitator, in talking to area farmers, can identify the barriers that might exist to adopting
agricultural BMPs to reduce phosphorus, and you can use those barriers to target your message.
Are finances a barrier to BMP implementation? Explain how your funding, agricultural conservation
grants and other sources can help farmers financially. Is lack of familiarity with certain BMPs a
barrier? Your facilitator can meet with farmers to educate them about options available to them.
Generic outreach materials can help explain the basics of adaptive management, but will most likely
not be as effective as materials geared to your specific audience.

Different Types of Messages

Education

General education can be the first step to encouraging BMP implementation. A possible barrier to
the adoption of BMPs is the lack of familiarity with the process of phosphorus pollution and its
solutions. For example, farmers might not be aware of watershed processes that carry runoff from
their farms to lakes and streams miles away. In your communication strategy, you may want to
ensure that farmers and other stakeholders are familiar with the following concepts:

 How phosphorus pollution diminishes water quality

 How phosphorus applied to fields ends up in water bodies far downstream
 Sources of phosphorus pollution on farms
 BMPs that reduce phosphorus pollution
 Costs and benefits of various BMPs
 Sources of funding for phosphorus reduction measures

Depending on your budget and staffing, you can create a variety of outreach materials across
different media. Brochures, fact sheets, newsletters, and other deliverables can help reinforce your
message and spread the word about adaptive management. You can distribute supplementary
materials at meetings, presentations and direct visits to farms.

Educational materials are helpful as a supplement, but should not replace direct interaction. One of
the most effective ways to send a message to farmers is peer education. For example, a study of
farmers’ sources of information on conservation tillage showed that the highest percentage of
farmers learned about conservation tillage from other farmers than from any other education
method.27 Showing that runoff-reducing practices can be implemented and maintained on a
profitable farm can help encourage the adoption of those practices. You can build credibility for
these practices by facilitating farmer-to-farmer communication. Presentations, testimonials and
farm tours can show farmers and other stakeholders how local farmers have implemented BMPs on
their land.

27Sundermeier, Alan, L. Fleming Fallon, Jr., Hans D. Schmalzried and Luke Sundermeier, “Conservation
Tillage: Repackaging the Message for Farmers,” Journal of Extension
47(2009), http://www.joe.org/joe/2009april/rb6.php.
Real-World Example: Farmer Education in Two Wisconsin Watersheds
In the early 1990s, educators from UW Cooperative Extension worked with dairy farmers in two
watersheds that contained waterways impaired due to phosphorus. The purpose of this effort was
not only to reduce nutrient losses, but also to determine the communication methods most effective
in getting farmers to change their behavior.

In both watersheds, educators attempted to get farmers to improve their nitrogen and phosphorus
applications to reduce nutrient loss. In one watershed, the extension educator focused efforts
mainly on one-on-one interaction with farmers. In the other watershed, a different extension
educator used a more general education approach, such as distributing educational materials and
spreading the word through local media.

Although there was some improvement in nutrient application in both watersheds, there was a
more pronounced result in the watershed where the extension educator worked more closely with
individual farmers, rather than just disseminating information. This example reinforces the
importance of making farmer education a personalized, specific approach. You can read more about
this study at http://www.joe.org/joe/1999october/a2.php (Title: Making Our Nonpoint Source
Pollution Education Programs Effective).

Marketing

When purely educational programs fail to spur behavior change among producers, it may help to
“brand” your AMO plan. Creating a brand increases the visibility of the project and helps the
audience remember the message. Effective branding also highlights the benefits of the desired
behavior change to the target audience. Marketing differs from education because it directly
encourages a specific action by the target audience, while education only spreads information.

Choosing how you want to market your plan depends on the perceived barriers to adaptive
management among your audience. If, for example, a major barrier is the fear that adopting BMPs
will diminish yields or overall farm profit, target your message to dispel those fears. Although it’s
difficult to quantify specific financial results of conservation practices, you can focus on proven
benefits of various conservation practices. For example, here are a few messages that focus on the
personal benefits of conservation practices for farmers:

 Cover crops can reduce erosion and nutrient loss from fields.
 Properly run grazing operations have reduced production costs compared to confined
feeding operations.28
 No-till agriculture can reduce soil moisture losses during and after a drought.29

Meanwhile, you can build awareness and support among conservation-minded farmers and
members of the public by emphasizing the environmental benefits of the AMO – improved habitat,
stronger ecosystems and healthier wildlife populations.

28 Natural Resources Conservation Service, “Profitable Grazing-Based Dairy Operations,”

2007.http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1044245.pdf.
29 “No-Till Farming Critical for Preventing Loss of Soil Moisture During Drought Conditions,” Natural

Resources Conservation Service, 2012,http://www.ia.nrcs.usda.gov/news/newsreleases/2012/SoilMoisture.html .

Part of the marketing aspect of your plan could be publicizing your project in the local media
through press releases and feature articles. Spreading the word about the AMO can help attract
partners, volunteers and funding.

Real-World Example: GrassWorks Pasture Walks

Managed grazing, when done correctly, has several environmental and economic advantages over
conventional feeding operations. Grazing, when compared to conventional livestock feeding, can
improve soil quality and stability, increase the number of native plant species and save the farmer
labor and input costs. However, grazing can come with stigma among farmers who view it as more
labor-intensive or less efficient than conventional feeding.

A Wisconsin nonprofit organization devoted to promoting grazing, GrassWorks, helps overcome

perceived barriers to grazing by leading “pasture walks,” which are informal tours of farms that
have implemented grazing. Tour participants learn about what methods have and haven’t worked
for the farmer and see in person how a grazing operation is run. On-site visits like these can
alleviate concerns or hesitations that farmers might have about adopting more sustainable
practices on their own land. Visits can also give farmers a better idea of what they might want to try
on their operations.

GrassWorks also provides additional resources for farmers considering a grazing transition. For
more information about this organization, visit their website at http://grassworks.org/?110380.

Collaborative Strategies

As a part of your plan, you’ll already be collaborating with many different stakeholders. Along the
same lines as creating a binding agreement with stakeholders, creating an official group or
association can increase a sense of accountability and support among involved parties. Organized
groups can also facilitate discussion among diverse groups of stakeholders and keep everyone
updated about progress in the project.

For example, for the Yahara Lakes pilot project explained below, a group of farmers and other
stakeholders voluntarily banded together to form a group called Yahara Pride. The group describes
itself on its website as a “self-regulated, self-recognized, and self-incentivized organization to
improve and protect our land and waterways in Dane County.” Farmer members have begun
implementing a cover crop program to reduce phosphorus runoff in the Yahara watershed. Having
a farmers’ association makes it easier for farmers to share information and techniques with one
another and to communication with other involved stakeholders.

Farmers’ collaborations can also provide valuable leadership and credibility. As mentioned in the
previous section, peer education is one of the most effective outreach methods for changing
behavior. Having an organized venue for sharing ideas and success stories about BMP
implementation can increase the chance that additional farmers will adopt such practices.

There may be funding available for the formation of collaborative groups. For example, River
Planning and Protection grants, offered through the DNR, can fund the creation of a river
management organization if applicants meet the criteria for the grant.30

30“River Protection Planning & River Protection Management Grants,” Wisconsin Department of Natural
Resources, last modified December 6, 2012, http://dnr.wi.gov/Aid/Rivers.html.
Pilot Strategies

Because the AMO is a new approach to water conservation and there are many variables involved,
it’s difficult to predict outcomes of various management practices. There are several models
available to estimate phosphorus reductions, but the real-world effectiveness of your plan will only
be clear after BMP implementation. If resources are available, consider launching a pilot project on
a smaller scale to test the effectiveness of the chosen practices before implementing the plan on a
larger scale. Pilot projects can provide lessons and guidance for further actions in the plan on a
larger scale.

Note that pilot projects won’t be feasible for many facilities. Pilot projects require ample time to
design and implement, and if your time or budget for meeting water quality criteria is limited, a
pilot project will likely be out of your scope. However, Clean Wisconsin is currently working with
stakeholders in selected areas of the state to guide pilot project planning and implementation. If
you don’t have the resources or time to conduct a pilot project of your own, these projects can help
inform your project planning. As these pilot projects advance, Clean Wisconsin will update this
handbook with lessons learned and recommendations from these projects.

Yahara Lakes Pilot Project

Dane County, Wisconsin is home to a mix of intensive agriculture operations and urban growth.
These environmental stressors have caused heavy phosphorus loading into the Yahara chain of
lakes, which includes Lake Mendota in Madison. The area’s main point source of phosphorus is the
Madison Metropolitan Sewerage District (MMSD), which serves several communities including
Madison, Monona, Middleton, Waunakee and Fitchburg. Although the MMSD is a relatively large,
technologically advanced wastewater treatment plant, it would still be economically and
environmentally inefficient for MMSD to reach phosphorus standards through plant upgrades
alone.

The regulatory driver for the Yahara pilot project is the Rock River TMDL, which establishes an
acceptable level of phosphorus in bodies of water that include the Yahara chain of lakes and the
Yahara River. MMSD, as one of the only permitted phosphorus dischargers in the area, is
responsible for meeting the water quality requirement of the TMDL.

The pilot project is estimated to take four years. It’s being implemented on a sub-watershed scale to
make it easier to implement and evaluate phosphorus reduction strategies before they’re applied in
other areas or on a larger scale.

The pilot project is estimated to cost about $3 million. $1.3 million of the project costs are coming
from a grant from the Mississippi River Basin Initiative (MRBI), and another $1.3 million are
coming from municipal partners. The rest of the project is being funded by smaller grants and
contributions. According to Dane County Executive Joe Parisi, as reported by the Wisconsin State
Journal, treating phosphorus at its source could be up to 75 percent cheaper than implementing
new point source technologies to comply with phosphorus standards.

Partner organizations, aside from MMSD and Clean Wisconsin, include Dane County, 21 towns,
villages and cities with stormwater discharges identified in the TMDL, the Clean Lakes Alliance, the
Sand County Foundation and a farmers’ coalition called Yahara Pride. The Dane County Land and
Water Resource Department is acting as the broker between different stakeholders.
The strategies anticipated to be used in the pilot project include the following:

 BMPs
o Dane County cover crop program
o Cost-share for feedlot roofs
o Vegetative buffers along stream banks
o Other agricultural best management practices
 Strategic communication
 Strong collaboration with farmers and formation of farmers’ group

For more information about the project, visit the project website
at http://www.madsewer.org/YaharaWINsHome.htm (Title: Yahara Watershed Improvement
Network).

Verifying Compliance

To help ensure that phosphorus-reducing practices are being implemented and maintained
correctly, you will need to have a mechanism of verifying compliance with agreements. You
facilitator or other agricultural liaison can evaluate BMP implementations for proper
implementation and maintenance. However, there may be situations where landowners are
noncompliant with environmental standards and do not respond to education or marketing. These
situations may require enforcement actions. Because a major focus of the AMO is collaboration, we
recommend that enforcement be used as a last resort.

Operators at point source facilities should not be directly responsible for enforcement actions.
These actions should be the responsibility of organizations with an enforcement or regulatory arm,
such as the DNR or certain environmental groups. However, the strategy for adaptive management
can proactively address issues of compliance by establishing agreements or rules in advance, such
as:

 Cost-share agreements. Creating contractual agreements with landowners and other

involved entities is critical to establishing accountability and clearly defining expected
actions. That way, the funder has a written guarantee that the funds will be used
appropriately.
 Ordinances. Municipality or county-wide ordinances can level the playing field for
landowners in terms of environmental standards or allowed practices. For example,
shoreland ordinances in a lake community can specify that a certain proportion of shoreline
must remain in natural vegetation.

Real-World Example: Dane County’s Nutrient Ordinances

Between 2004 and 2005, manure runoff events led to more than a dozen fish kills in
Wisconsin.31 Several of these fish kills occurred in Dane County, prompting the Dane County Board
to enact ordinances related to manure storage and spreading and to fertilizer application on lawns
or other land.

One of the main ordinances is a restriction on winter application of manure, since manure runs off

31“Manure Runoff Media Kit,” Wisconsin Department of Natural Resources, last modified December 18,
2012,http://dnr.wi.gov/news/mediakits/mk_manure_runoff.asp.
of frozen fields more readily than it does off of unfrozen fields. Although the winter spreading
ordinance still allows for some winter manure application under a permit, it comes with additional
safeguards against significant runoff events. For example, winter manure spreading is prohibited
within 30 feet of a waterway, and the amount of manure allowed for spreading decreases as the
slope of the field increases.

Additional county ordinances require manure storage facilities to meet certain technical standards
and prohibit most applications of phosphorus-containing fertilizers to lawns. Violations of these
ordinances can result in fines. For additional information about these ordinances and other
strategies for controlling runoff in Dane County, go to the Dane County Office of Lakes and
Watersheds website at http://www.danewaters.com.

7-3: Develop the Implementation Plan

The formal request form for the AMO requires an AMO plan. By completing the previous actions in
this handbook, you’ll already have the information you need for the plan you submit to the DNR.

To get approval for your AMO plan and have it incorporated into your WPDES permit, you must
completely supply all the required information for the DNR’s AMO request form, explained below,
in addition to a complete AMO plan. However, your plan may incorporate aspects beyond the DNR’s
requirements. For example, while the DNR doesn’t require individual fields or farms identified as
part of the submitted AMO request, your full plan may still involve specific farms if you’ve made
agreements with individual farmers to implement BMPs.

Also, DNR’s requirements for an AMO plan do not includes the establishment of a formal agreement
with partners, one strategy that may contribute to success. The AMO plan and request form you
submit to the DNR will provide a solid basis for implementation, but keep in mind that you can
supplement your plan with additional information.

Meet DNR Requirements for an AMO Plan

The DNR has a detailed technical guidance on the requirements for a complete AMO plan. To ensure
that your AMO plan includes the required elements, we recommend consulting this guidance as you
complete the AMO plan and fill out your AMO request form. This guidance is available
at http://dnr.wi.gov/topic/surfacewater/adaptivemanagement.html.

When reviewing submitted AMO request forms, DNR staff will be looking for the following nine
elements:

 Identify major phosphorus contributors

 Quantify load reductions needed
 Identify partners
 Describe management measures
 Identify where load reductions will occur
 Estimate load reductions expected from strategies
 Monitoring
 Financial security
  Implementation schedule and milestones

According to the DNR, if your AMO plan completely and accurately addressed the nine key elements
above, and you fill out each section of the AMO request form, you should have satisfied the required
elements for adaptive management. If you have questions about the requirements on the AMO plan
or the request form, you can contact your regional adaptive management coordinator or
wastewater engineer or specialist.

Additional Resources for Developing the Plan

Although the DNR’s request form for the AMO will guide you through the required elements for an
AMO plan, you may use additional resources in the planning process to organize information or find
recommendations if you choose. This section includes links to existing or completed watershed
projects to give you an idea about strategies that have worked in the past. It also includes a link to
the EPA Watershed Builder, an online tool you may use to organize information.

Learning from Previous Projects

Looking at existing watershed plans, in addition to giving you an idea of how to structure your AMO
plan, can show what strategies have been successful and what strategies have failed. Although the
viability and success of a given strategy depends on local conditions, current or completed projects
can be valuable resources.

As a reminder: before you begin drafting your own plan, check first to find any existing watershed
plans or TMDL reports in your watershed. You may be able to merge efforts or incorporate data
from those plans into your AMO plan. For Wisconsin water bodies with an approved TMDL, go
to http://dnr.wi.gov/topic/impairedwaters/approved_tmdls.html (Title: Approved TMDL Waters).
For a list of watershed plans active as of 2011, go
to http://dnr.wi.gov/topic/surfacewater/planning.html (Title: Wisconsin Water Planning).

The U.S. EPA has a site devoted to nonpoint source pollution reduction success stories. This site has
state-specific links to descriptions of projects that successfully reduced nonpoint source pollution.
The descriptions include an overview of the issue that was addressed, actions taken, major partners
and funding that helped get the job done. These descriptions show what has worked in watershed
management and can give you an idea of how to effectively use resources and partnerships. These
stories, including several projects from Wisconsin, are at the following
link:http://water.epa.gov/polwaste/nps/success319/#restored (Title: Section 319 Nonpoint
Source Success Stories).

Meanwhile, you can also learn from plans that weren’t as successful. The box below includes a real-
life example of an unsuccessful phosphorus reduction effort in Vermont and highlights the lessons
learned from this project.

Real-World Example: The Lake Champlain TMDL

Lake Champlain is a large lake in Vermont with high levels of phosphorus loading due to point
source discharges and agricultural runoff. In 2002, the U.S. EPA approved a TMDL for the lake with
the goal of reducing phosphorus to a healthier level. However, significant phosphorus reductions
did not occur after approval of the TMDL. In fact, phosphorus loading actually increased in some
places. In 2011, U.S. EPA withdrew its approval of the Lake Champlain TMDL, citing two specific
reasons:

1. Over-generalized predictions of margin of safety (MOS)

The 2002 TMDL included a calculated MOS as a safeguard for variations between the predicted and
actual phosphorus load reductions due to the TMDL. The U.S. EPA found that the MOS from the
2002 TMDL was too general and did not account for conditions in specific sections of the lake.
Although the MOS applied to certain segments of the lake, particularly those more directly affected
by point source phosphorus pollution, it did not adequately account for other segments of the lake,
like those more directly affected by runoff. This example highlights the need for solid data gathering
and analysis, careful development of the action area and conservative estimates of phosphorus
reductions.

2. Lack of accountability for proposed management measures

The 2002 TMDL allowed point sources higher wasteload allocations (WLAs, which are similar to
WQBELs) than the levels required to attain water quality standards in Lake Champlain. The higher
WLAs were justified by several planned strategies to reduce nonpoint phosphorus pollution,
including stream bank restoration and using Farm Bill funding for conservation programs.

However, as the U.S. EPA pointed out, the success of this strategy relied on sufficient funding,
cooperation from private landowners and participation by volunteers. The program, lacking full
participation, was less effective than planned. This scenario illustrates why it’s vitally important to
build strong partnerships at the outset of your plan and to establish binding agreements with
partners.

Source: http://www.epa.gov/region1/eco/tmdl/pdfs/vt/LakeChamplainTMDLDisapprovalDecisio
n.pdf

Using the U.S. EPA Watershed Builder to Organize Your Plan

The U.S. EPA has a useful tool for outlining your AMO plan, organizing the data you’ve collected and
finding additional information about your watershed. The Watershed Builder can be a good starting
point for drafting your plan and determining what information you still need. With this tool, you
can:

 Select your watershed or manually draw your action area.

 Enter the goals and drivers for your plan, the threats to water quality and land
use/activities in the watershed. For example, you can enter a driver of “Improve water
quality,” a regulatory driver of “Meet water quality standards,” a pollutant of “Phosphorus
compounds” and water quality concerns of “Polluted runoff” and “Impaired water quality.”
 List the names, contact information and role of stakeholders involved in your plan.
 View a summary of environmental data about your watershed, including 303(d) impaired
waters and sources of pollution in the area.
 Download watershed monitoring data and information about facilities in the area.
 Download an outline into Microsoft Word that you can use as a starting point for the plan
description.
This tool won’t replace the need for an experienced conservationist or consultant to help develop
your plan, but the builder can provide a framework for the plan and can help facilities with limited
resources and staff to outline a plan in-house. The Watershed Plan Builder is available
athttp://java.epa.gov/wsplanner/#.

Keep in mind that this tool applies to developing broad watershed plans rather than AMO plans.
Elements of watershed planning overlap with AMO planning, since the AMO is a watershed-scale
strategy, but keep your plan’s focus on meeting your facility’s effluent limits.
Chapter 8: Implement and Adapt the Plan
After your AMO plan has been approved, you can begin putting the information you’ve gathered
into practice. This chapter includes what to expect in your WPDES permit with an AMO plan and the
general process for deciding on adaptations if the plan isn’t working out as expected.

In this section:
8-1: Permit Requirements for the AMO
Actions related to the AMO that will be incorporated into your
facility's WPDES permit
8-2: Monitor and Report Water Quality Data
Assess the effectiveness of implemented BMPs in reducing
phosphorus levels.
8-3: Assess and Adapt the Plan Based on Results
Bring together your gathered data, identified partners, funding
sources and management measures into a plan for submittal to
the DNR.
8-4: Mitigating Risks of the AMO
Strategies to increase the likelihood of success of your AMO plan.

8-1: Permit Requirements for the AMO

The permit reissued with an approved AMO plan will be similar to previous WPDES permits with
minor differences to account for AMO measures. The permit will include the following information:

 The interim WQBELs for each permit term

 A compliance schedule for achieving limits, if necessary
 The phosphorus reduction actions in the AMO plan
 The DNR’s monitoring requirements
 The reporting requirements for the plan’s progress
 Provisions for failure to implement the plan
 Reasons for termination

Like other WPDES permits, permits that include an AMO plan are subject to public notice and
review, and the annual reports to the DNR are public record.

In researching and drafting your AMO request form, you will already have the information for the
first three points above.

8-2: Monitor and Report Water Quality Data

The requirements for monitoring phosphorus and reporting actions and outcomes will be built into
your permit with an approved AMO plan. When you receive your permit, the DNR will provide the
required method, location and frequency of water monitoring at your facility. To assess the
effectiveness of implemented BMPs across the watershed, water monitoring should be done not
only at your facility, but at strategic monitoring locations in the action area. A county
conservationist or other water science expert can help determine where monitoring sites would be
helpful.

For assistance with watershed-wide water monitoring, you have a close-to-home resource in citizen
water monitoring groups. These groups enlist volunteers to measure and report water quality. See
the Potential Partners section for additional information about water quality monitoring groups.

However monitoring is conducted, the DNR will require quality controls and approved methods for
collection and testing. Monitoring requirements for the AMO are explained in more detail in the
DNR’s technical handbook on the AMO.

Your permit will also contain requirements for reporting on the progress of your AMO plan. As you
implement the AMO plan, you will need to submit a yearly report to the DNR that describes your
progress toward achieving your goals. The monitoring data you collect will quantify progress your
plan has made toward water quality improvement.

8-3: Assess and Adapt the Plan Based on Results

As you prepare your yearly report on progress of your AMO plan, you might discover that the plan
isn’t achieving its goals as initially predicted. Water phosphorus levels might not be decreasing as
planned, your budget may be stretched or a partner might not be pulling their weight. This is where
the “adaptive” part of adaptive management comes in -- under this strategy, you are continually
evaluating and adjusting the plan based on results. The following section outlines potential issues
you might encounter and actions you can take to try to solve them.

In general, the approaches you take toward adaptations will repeat steps you took during the
planning process: gathering data, analyzing the data to find the source of the problem, and
developing a plan to address that problem. Adjusting the plan based on outcomes is where the AMO
intersects with the more general concept of adaptive management.

Issue: Phosphorus load reduction goals aren’t being met

Adaptation: How you approach this problem depends on the reason why the desired phosphorus
levels aren’t being achieved. For example, you don’t want to spend the time and money
implementing another agricultural BMP if it turns out that the issue is a lack of compliance on the
part of a farmer. Before you plan an adaptation, analyze the cause of the problem. This process will
mirror the basic structure of your initial data-gathering and modeling, except at this point you’ll
have more real-world data to use from stream monitoring.
Before you begin adapting the plan, ask the following questions:

 Was current data used when modeling phosphorus loading? If not, your model might not
have generated the best estimate. If possible, re-model the action area with data from the
past year and determine whether the actions in your plan are still sufficient to meet
phosphorus goals. If not, you may have to add additional actions to your plan.
 Was there an unusual weather event over the past year? Intense storms or flooding might
have affected phosphorus levels in bodies of water. For example, if a vegetative buffer were
flooded or completely saturated, it would not be as effective as it would be under normal
 circumstances. Consider altering your plan to allow for extreme weather events. (This is one
reason it’s recommended to set your phosphorus load reduction goal over the load
reduction required to meet assigned water quality standards.)
 Were BMPs implemented in the right location? For example, if the receiving water just
downstream from a stretch of vegetative buffer shows improvements, but phosphorus
levels jump at an un-buffered section of stream bank downstream, the vegetative buffer
might not be in the most effective part of the stream bank.
 Have the BMPs been given enough time to work? In some cases, it will take many years to
see the full effects of BMPs on water quality. This is not to say that properly implemented
BMPs will not have a noticeable effect during the permit period; however, just because a
given BMP has not yet achieved expected results does not mean that it’s not effective. If this
is the case, continue regular monitoring of the site with the BMP and include your
monitoring plan in the report.
 Are the farmers correctly maintaining or complying with the BMPs implemented on their
land? Your facilitator should regularly visit farms to ensure that BMPs are being managed
appropriately. If a farmer mows 15 feet of a 30-foot-wide vegetative buffer, its phosphorus
reduction capability will decrease considerably. If compliance is an issue, target outreach
and monitoring efforts to that area.

In some cases, the root cause will be difficult to determine. Models differ from the real world, and
the chosen BMPs might not achieve predicted phosphorus load reductions even when implemented
correctly. In this case, consider ramping up the monitoring aspect of the plan to determine where
the biggest problems still exist. You can also consider alternative BMPs to implement than those
initially chosen.

Issue: The plan implementation is costing more than expected

Adaptations: In the case of stretched finances, you have a few options to consider: you can find
ways to lessen the cost of existing actions, implement less expensive actions or obtain additional
funding.

For example, consider the following questions:

 Are there any actions you’re paying for that your or volunteers could perform? For example,
if you’re paying someone to monitor stream quality, you could consider reaching out to a
nonprofit organization or citizen water monitoring group to find volunteers to assist in
monitoring. Meanwhile, you or your staff could receive training on actions you could take
yourself. For example, the Wisconsin Rural Water Association provides sampling and
monitoring classes, among other training, to water treatment operators.
 Are partner farmers already receiving federal assistance for conservation practices? As
outlined in the Estimating Costs and Obtaining Funding section, there are many
conservation grant and loan opportunities for farmers. If you have a broker working with
farmers, such as a conservationist or USDA field agent, work with them to make sure that
the farmers are aware of the funding they’re eligible for and that they have applied or are
planning to apply for funding.
 Have you approached all potential municipal or industrial partners in the watershed? One
of the advantages of the AMO is the possibility of defraying costs among affected
stakeholders. Emphasize the indirect financial benefits of the AMO to municipalities –
 increased property values, higher quality of life, healthier community – to bring additional
partners on board.

Your AMO plan will involve a mix of different strategies, some successful, others not as successful.
One of the main objectives for adaptive management is to adjust the plan based on initial lessons
and additional information so that it becomes more and more effective as time goes on. In the long
run, these lessons will help protect the waters in your watershed and across Wisconsin.

8-4: Mitigating Risks of the AMO

The AMO can be an effective, low-cost alternative to traditional water quality upgrades, but this
strategy is not without risks. It’s important to acknowledge the risks associated with the AMO so
that you’ll be able to better anticipate and address possible issues that arise during planning and
implementation.

The main risk of the AMO is that your facility will not meet its assigned WQBEL by the scheduled
date. If this situation occurs, your facility will likely need to make facility upgrades to meet the
required effluent limit. However, under the AMO, even some improvement to water quality will
affect the standards applied to area point sources. The DNR will recalculate WQBELs based on
current phosphorus levels in the receiving water, so the new WQBEL might be less stringent at the
end of the two permit terms under the AMO plan. As a result, even if you still have to make
technological upgrades to your facility, they could be minor compared to the facility upgrades you
would have to make now to attain your WQBEL.

Although there can’t be a guarantee of success through the AMO, there are several steps you can
take to mitigate risks and to increase the likelihood of success. Some of these steps have been
covered elsewhere in this handbook, but they’re summarized here:

 Get started early. If possible, determine your eligibility for the AMO and create a plan before
the next permit reissuance process begins for your facility. The earlier you begin, the more
time you have to implement phosphorus-reducing practices before the final WQBEL for
your facility takes effect.
 Build strong partnerships right away. Although many tools exist for helping you gather data
and draft a plan, your best resources will be local partners. Solid, constructive relationships
will keep the plan moving and fill in gaps in data, skills and funding.
 Communicate clearly and regularly with stakeholders and community members. Regular
meetings will keep stakeholders informed and maintain partnerships, and updates to the
community can build support for the project and possibly attract new partners or
assistance.
 Focus on getting farmers and landowners engaged in the plan. A facilitator with solid
knowledge of local agriculture can be instrumental in getting farmers to adopt phosphorus-
reducing BMPs. Demonstrating that farmers can implement and maintain BMPs on a
profitable farm may encourage other area farmers to adopt those practices as well.
 Increase accountability for partners. Obtain binding agreements from stakeholders that
ensure shared responsibility for funding or implementation of the plan.
 Develop a comprehensive monitoring plan. Since water quality data will be the basis for
planning and BMP selection, it’s crucial that the data is complete, current and accurate.
Ensure that regular water monitoring is conducted at relevant points in the watershed and
that the collection and analysis methods are sound.
  Overshoot minimum requirements. For example, plan to meet interim effluent limits by
year 3 rather than the end of the permit term. Similarly, if resources allow, implement
practices that are projected to reduce phosphorus loads over the minimum reduction
needed to meet limits. Setting goals above minimum standards gives you a margin of
insurance in case real-world results differ from modeled projections.

Overall, any phosphorus reduction strategy – the AMO, facility upgrades or water quality trading –
is designed to mitigate the risk of further water quality degradation. The difference between the
AMO and the other two options is that the AMO directly attempts to meet water quality standards,
while facility upgrades and water quality trading attempt to meet water quality standards
indirectly through strict effluent limits or offsets. By addressing water quality standards directly,
the AMO reduces the risk of water quality degradation down the line.
Appendix A: Worksheet for Determining P Load
Reductions
Use the following worksheet to determine the proportion of phosphorus that your facility
contributes to the overall phosphorus in your receiving water (as described in the Phase II –
Analyze Data section). Then, use that proportion to determine the phosphorus load reduction for
which your facility is initially responsible.

Your facility’s design capacity: ________________MGD

A
Your facility’s average long-term effluent phosphorus effluent level: _________________mg/L
B
Average annual flow of your facility’s receiving water: _________________MGD
C
Background concentration of phosphorus in the receiving water*: _________________mg/L
D

*This measurement should come from monitoring data taken just upstream from the facility’s
discharge source, so there are no other significant phosphorus loads between the monitoring point
and the facility’s discharge. You can use the SWDV to determine background P concentrations, if
monitoring data is available.

To find your facility’s annual phosphorus load in pounds per year (E), plug the above data into the
following equation. This equation uses 8.34 as a conversion factor.

______________MGD x ______________mg/L x 8.34 x 365 days/year = _________________lbs./year

A B E

Then, find the phosphorus load upstream of your facility in pounds per year (F):

______________mg/L x ______________MGD x 8.34 x 365 days/year = ______________lbs./year

D C F

The current phosphorus load of your facility’s receiving water (G) is the sum of your facility’s
annual phosphorus load and the upstream phosphorus load:

______________lbs./year + ______________lbs./year = ______________lbs./year

E F G

Then, just divide the total phosphorus load by your facility’s phosphorus load to determine your
facility’s percent contribution (H) to phosphorus in the receiving water:

______________lbs./year / ______________lbs./year = ______________

E G H
______________ x 100 = ______________%
H

The DNR has an example calculation of proportional phosphorus load contributions in its guidance
document.

Once the percent phosphorus contribution is determined, the next step is to use that percentage to
determine the amount of pollution offset for which the facility is responsible. The facility’s WQBEL
is necessary for this calculation. If you do not yet have the WQBEL for the upcoming permit term,
you can take one of the actions below:
 Use the WQBEL from your current permit, if available, for purposes of estimation.
 Request the upcoming WQBEL from the DNR.
 Calculate your new WQBEL based on current phosphorus data (see page X).
To calculate the phosphorus load reduction for which your facility is responsible, use the equations
below.

The acceptable annual phosphorus load in your facility’s receiving water (I) depends on your
facility’s WQBEL:

(___________MGD + ___________MGD) x ___________ x 8.34 x 365 days/year = ___________lbs./year

A C WQBEL I

The necessary load reductions (J) are the difference between the current load and the acceptable
load:

______________lbs./year - ______________lbs./year = ______________lbs./year

G I J

Last, determine the load reductions for which your facility is initially responsible:

______________lbs./year x ______________ = ______________lbs./year

J H
Appendix B: Potential Partners
The following is a partial list of partners that could help plan, implement or finance your project. It
is not a definitive list, but is meant to give you an idea of the types of organizations that could be
necessary or generally helpful partners in your plan. This section also contains examples of how
partners could help with your plan and, when relevant, contact information for the organization.

Note: The organizations in this section are listed only as possible partners, and their inclusion in this
handbook does not guarantee that they will be able or willing to assist in your AMO plan. Conversely,
your plan may incorporate partners that are not listed in this section.

Citizen Water Monitoring Programs

About: There are several volunteer-based water quality monitoring programs in Wisconsin.
Depending on experience or expertise, volunteers with these programs measure
benchmarks of water health, such as clarity, nutrient levels and dissolved oxygen
concentrations. In some programs, there is the opportunity for more robust testing. For
example, the statewide Citizen-Based Water Monitoring Network includes several
monitoring programs with three levels of complexity, starting with Level 1 for beginners
and working up to Level 3 for special monitoring projects.

How They Can Help: Volunteer monitoring can be a valuable resource to permittees with
limited budget or staff for watershed-level water quality monitoring. Although the type of
monitoring varies, volunteers may be trained to collect samples for phosphorus testing.

Contacts: For a list of some citizen monitoring programs in Wisconsin, go to

http://yosemite.epa.gov/water/volmon.nsf/VST!OpenView&Start=30&Count=30&Expand=
49#49. Active water monitoring programs may also be listed when you use the U.S. EPA
Surf Your Watershed feature or the DNR’s watershed search tool.

For information about the Citizen-Based Water Monitoring Network, go

to http://watermonitoring.uwex.edu/index.html.

County Land and Water Conservation Committees

About: LCCs, which are made up of county board officials, determine conservation policy
for their county and assist residents with conservation programs. These committees
determine the conservation actions carried out by land and water conservation
departments.

How They Can Help: LCCs may create policy and regulatory incentive for adaptive
management implementation. For example, your local LCC can allocate staff or other
resources to farmer outreach or enforcement of water standards. You can also work with
LCCs to determine the best overall water management plan for the county, incorporating
other conservation goals. As an additional incentive for compliance, LCCs may develop local
ordinances related to phosphorus discharge or agricultural practices.
 Contacts: For the contact information for local conservation officials, including LCC
members, go
tohttp://datcp.wi.gov/Environment/Land_and_Water_Conservation/Land_and_Water_Cons
ervation_Directory/index.aspx and click the most recent Land & Water Conservation
Directory.

County Land and Water Conservation Departments

About: These divisions of county government are instrumental in helping implement

conservation programs and educating the public about natural resources.

How They Can Help: Conservation departments can provide information about soil and
water quality in the region, as well as land use data. The county conservationist will have
access to data about impaired waters in the county and sources of water pollution. For
example, the county conservationist may be able to identify agricultural operations that
might be significant sources of nutrient runoff in your watershed. The conservationist may
also provide outreach and assistance to farmers implementing conservation practices. The
county conservation office is a good place to approach when selecting a facilitator.

Contacts: For a list of land and water conservation departments by county, go

to http://wlwca.org/LCDWeb.html. For the contact information for local conservation
officials, go to
http://datcp.wi.gov/Environment/Land_and_Water_Conservation/Land_and_Water_Conser
vation_Directory/index.aspx and click the most recent Land & Water Conservation
Directory.

Department of Agriculture, Trade and Consumer Protection (DATCP)

About: DATCP oversees agricultural and business-related policy and regulation in

Wisconsin. The department administers several programs related to conservation and
water protection, including nutrient management planning and livestock siting. DATCP
works closely with counties to administer funding and approval to county land and water
conservation plans. Within DATCP, the Land and Water Conservation Board (LWCB), which
is made up of state and county officials involved in resource management, reviews
conservation plans and recommends allocation of funding to counties.

How They Can Help: DATCP will be more of an indirect partner to individual facilities, and
will work more directly with county conservation departments. Your county may include a
watershed AMO plan as part of its overall conservation plan, in which case the LWCB may
weigh in on the plan.

Contacts: The main DATCP office number is 608-224-5012. For the Department of
Agricultural Resource Management, call 608-224-4500. For other contact numbers, go
to http://datcp.wi.gov/Contacts/index.aspx.

Environmental Advocacy Groups

 About: Wisconsin is home to several environmental advocacy groups that focus on diverse
topics from policy to law to grassroots organization. In addition to Clean Wisconsin, some
prominent statewide groups include the River Alliance of Wisconsin, the Sierra Club-John
Muir Chapter and the Sand County Foundation. There are many more local chapters and
groups that also might be able to assist you.

How They Can Help: As nonprofit organizations, environmental advocacy groups can be
eligible for certain grants and funding for aspects of your plan, such as water monitoring
and BMP construction. Such organizations often have volunteer networks that can assist in
research or monitoring efforts. Some environmental groups also lobby heavily for
environmentally friendly legislation and can help push for policy that will assist in adaptive
management implementation. Meanwhile environmental law groups like the Environmental
Law and Policy Center (ELPC) and Midwest Environmental Advocates (MEA) can assist in
verifying compliance with clean water laws.

Contacts:
 Clean Wisconsin: 608-251-7020 or http://www.cleanwisconsin.org
 River Alliance of Wisconsin: 608-257-2424 or http://www.wisconsinrivers.org
 Sierra Club-John Muir Chapter: 608-256-0565 or www.wisconsin.sierraclub.org
 Sand County Foundation: 608-663-4605 or http://sandcounty.net
 Environmental Law and Policy Center: 608-442-6998 or http://www.elpc.org
 Midwest Environmental Advocates (Madison office): 608-251-5047
or http://midwestadvocates.org
 Other groups: the U.S. EPA Surf Your Watershed feature or the DNR’s watershed
search tool may list environmental advocacy groups in your area.

Hunter/Sportsmen’s Groups

About: Wisconsin’s hunters and fishermen can be avid conservationists. The Wisconsin
branches of sportsmen’s groups such as Ducks Unlimited and Trout Unlimited advocate for
water and habitat preservation. They provide funding for a variety of conservation projects,
such as wetland and habitat restoration in Wisconsin. Such groups also have volunteer
networks to help with conservation projects.

How They Can Help: The goals and projects of sportsmen’s groups can align with aspects
of an AMO plan. For example, wildfowl hunters’ groups are often interested in wetland
restoration to provide habitat for game. From a management perspective, wetland
restoration near agricultural land can create a natural “sponge” that reduces phosphorus
runoff into adjoining bodies of water. In addition, clean water clearly has an advantage to
fishermen and to hunters whose hunting dogs enter water. Sportsmen’s groups and
volunteers may be able to provide assistance with BMP implementation or funding for
restoration aspects of an AMO plan.

Contacts: For Ducks Unlimited regional staff contact information, go

to http://www.ducks.org/wisconsin/wisconsin-content/wisconsin-du-staff.
For Trout Unlimited Wisconsin staff contact information, go
to http://www.wisconsintu.org/WTU/Leadership/tabid/56/Default.aspx.
Land Trusts

About: Land trusts are organizations that purchase or rent land to protect and restore its
natural features. Land trusts often control land by purchasing conservation easements,
which are the rights to determining how a given tract of land can be used. When a land trust
purchases a conservation easement from a landowner, the landowner still owns the land,
but must manage the land as specified by the agreement with the land trust. For example, a
land trust could purchase a conservation easement from a farmer and specify that the land
must be kept as a vegetative buffer. In such agreements, land trusts establish partnerships
with landowners and other organizations to achieve their conservation goals.

How They Can Help: You can partner with a land trust to work on purchasing or renting
conservation easements on land that would benefit from runoff management practices. This
ownership gives you more control over conservation practices on the land.

Contacts: The Gathering Waters Conservancy is a statewide resource for local land trusts.
Go to http://www.gatheringwaters.org/about-land-trusts/find-a-local-land-trust/ and click
on your county to find land trusts in your area.

Natural Resources Conservation Service (NRCS)

About: The NRCS is a branch of the USDA dedicated to land and water conservation. NRCS
agents gather data about local farming trends and environmental conditions. One of the
primary roles of the NRCS is providing technical assistance to farmers implementing
conservation practices. NRCS agents work directly with farmers to develop farm-specific
management plans and implement sustainable farming techniques. Much of NRCS’s
involvement in farm conservation programs is through federal agricultural assistance
programs like EQIP.

How They Can Help: NRCS staff may be “on-the-ground” resources for coming up with
strategies for farmers and implementing BMPs. Time- and staff-permitting, NRCS agents can
help producers evaluate the best BMPs for their operation and instruct them in proper
implementation. The NRCS also administers several financial assistance programs, such as
EQIP and the Conservation Stewardship Program (CSP).

Contacts: For a list of NRCS staff and service center locations in Wisconsin, go
to http://www.wi.nrcs.usda.gov/contact/office_search.html.

Parks Departments/Public Works Departments

About: Parks departments and public works departments are devoted to the use and
improvement of public spaces and infrastructure. For example, the Dane County public
works department is responsible for, among other things, the Dane County recycling
program and the removal of aquatic weeds from area lakes.

How They Can Help: Public works departments can provide support and manpower for
project implementation, such as the construction of urban runoff reducing BMPs. Reducing
phosphorus pollution will likely be in the best interest of these departments – improved
 water quality makes parks more pleasant and reduces the need for beach closings and weed
removal.

Contacts: Because these departments vary by location, the best way to contact your local
parks department or public works department is through the website for your municipality
or county.

Regional Planning Commissions

About: Regional planning commissions (RPCs) are groups that encourage economic and
structural development in various areas in Wisconsin. There are nine RPCs in Wisconsin
that serve all but five counties.

How They Can Help: RPCs can provide oversight and input to projects related to natural
resources, including restoration practices on public lands. RPCs may aid in the development
of local policy and ordinances related to phosphorus runoff control.

Contacts: The Wisconsin Department of Transportation maintains a list of statewide

regional planning commissions and their contact information
here:http://www.dot.state.wi.us/projects/planorg/docs/contacts.pdf.

Schools and Higher Education

About: Of the dozens of public and private universities and colleges across the state, many
have coursework and research programs related to water resources. Depending on the
school and the program, undergraduate and graduate programs may involve hands-on
experience in water management and outreach projects. Even high school science programs
may be available for assistance with water management projects. For example, the Hardies
Creek TMDL used data collected by students at a local high school.32

How They Can Help: In addition to faculty members providing expertise and research,
students can help in several areas of your plan as needed. For example, consider contacting
instructors in natural resources or communications departments to see if their classes could
be involved in some aspects of your AMO plan. Geography students studying GIS could
assist in mapping action areas and identifying vulnerable lands, environmental science
students could monitor water quality and communications students could help develop
outreach materials, to name a few possibilities. Although using student help has limitations,
such as a lack of experience or longevity, it may be a good way to supplement your efforts at
no cost. One example of student involvement in an adaptive management project is the
interim assessment of the Yahara pilot project, which was conducted by students in the UW-
Madison Zoology department to evaluate the project's success based on criteira laid out in
the project MOU.

Contacts: Will vary by area

32Helsel, Dan and Nicole Richmond. "Total Maximum Daily Load: Hardies Creek Trempealeau County, WI."
Wisconsin Department of Natural Resources
2008. http://dnr.wi.gov/topic/TMDLs/ApprovedTMDLs/HardiesCreekTMDLFinal.pdf .
United States Fish and Wildlife Service (FWS)

About: The FWS is the branch of federal government concerned with protecting wild
animal species and their habitats. Among other activities, the FWS administers the
Endangered Species Act, enforces environmental law and oversees conservation and
wildlife-related recreation programs.

How They Can Help: The FWS administers several grants related to wildlife and habitat
protection. Because excessive phosphorus is linked to fish kills and habitat degradation, the
FWS may be an interested partner or funding source for AMO plans.

Contacts: The various contacts for several types of Wisconsin FWS offices are listed
at http://www.fws.gov/midwest/news/wisconsin.html.

United States Geographical Survey (USGS)

About: The USGS is a research branch of the U.S. government that studies land, biological
and water systems. It runs several research programs, including a water program.

How They Can Help: The USGS has many water monitoring stations across the nation and
in Wisconsin that can provide watershed quality data. For example, the USGS established
water monitoring stations in the action area for the Yahara Lakes pilot project as part of its
partnership with the stakeholders.33 Because the USGS is a research institution and the AMO
is a relatively new approach to conservation, the USGS may be interested in assisting with
water or soil research related to your project.

Contacts: The contact information for various USGS programs in Wisconsin is available
at http://www.usgs.gov/contact_us/?state=WI.

University of Wisconsin Cooperative Extension

About: UW extension educators have an office in each country in Wisconsin. Their purpose
is to educate residents about topics relevant to the community, including agricultural and
environmental issues. UW-Extension also administers water quality monitoring programs
and applies research conducted on UW campuses.

How They Can Help: Extension educators can use their expertise and credibility to reach
out to the farming community. Educators with a background in agriculture may help
determine the most effective or appropriate BMPs to reduce phosphorus while maintaining
farm productivity.

Contacts: For a list of extension offices by country, go to http://www.uwex.edu/ces/cty.

To view or purchase Extension publications, go
to http://learningstore.uwex.edu/Default.aspx.

33 Dave Taylor, personal communication with author, September 10, 2012.

Watershed Associations/”Friends” Groups

About: Many local citizens care deeply about the quality of waters in their area. Often
comprised mostly of volunteers, citizen-led watershed associations act as stewards of their
watershed through restoration activities, fundraising and outreach. Your area might also
have a “friend group” for the watershed or a specific body of water, such as “Friends of Lake
Wingra,” that carry out similar actions.

How They Can Help: Depending on the size and level of involvement of watershed
associations in your area, local watershed associations or their volunteers can assist in
water quality monitoring and restoration efforts. Some watershed associations also raise
money for conservation projects and can be a source of funding for BMP implementation or
outreach.

Real-World Example: Stream Bank Restoration by the USRWA

The Upper Sugar River Watershed Association, a group of citizens in south-central

Wisconsin, organizes several projects related to water quality. For example, the
USRWA hosts “work parties” for volunteers to restore stream banks to reduce
erosion and maintain habitat. The work is typically done on public and private lands
with conservation easements. Members also participate in stream monitoring. For
additional information about this organization, visit http://www.usrwa.org.

Contacts: Varies by area. The River Alliance of Wisconsin’s website has a search tool you
can use to find local river groups at the following link:
http://www.wisconsinrivers.org/directory (Title: Wisconsin River Group Directory). If
you’re around Dane County, the Dane County Office of Lakes and Watersheds maintains a
directory of water advocacy organizations
here: http://danewaters.com/other/friends.aspx.

Otherwise, many of the watershed search features described in the What Is My Watershed?
section of Chapter 5 of this handbook include lists of local watershed groups and their
contact information.

Wisconsin Department of Natural Resources

About: The DNR manages, monitors and enforces environmental standards in Wisconsin.
The DNR will be reviewing and approving AMO plans and verifying compliance with permit
requirements.

How They Can Help: The DNR, as the regulatory agency behind the phosphorus rule, has
large amounts of data about water quality, state watersheds, planning and policy. The DNR
has tools specifically designed to identify phosphorus-impaired waters in the state and the
sources of their pollution, such as the SWDV and PRESTO. As you evaluate the AMO and
develop an AMO plan, you may work with the DNR to obtain your WQBEL, and to discuss
various aspects of your AMO plan. DNR resources such as the watershed search tool can
also provide background information for your plan. Regional adaptive management
 coordinators are available to answer questions about the AMO and provide technical
assistance, as necessary.

Contacts: The primary contact at the DNR for questions about the AMO is Amanda Minks
(amanda.minks@wisconsin.gov). You can find additional DNR resources for the AMO
at http://dnr.wi.gov/topic/surfacewater/adaptivemanagement.html.

For questions about water quality modeling, you can contact the modeling team
at dnrwaterqualitymodeling@wisconsin.gov.

Wisconsin Rural Water Association (WRWA)

About: The WRWA provides technical assistance, education and financial resources to its
members statewide, which include municipalities and non-municipal wastewater
dischargers. Members range in size, but the WRWA particularly focuses on constituents that
serve municipalities with fewer than 10,000 residents.

How They Can Help: WRWA circuit riders (technical outreach staff) provide training and
technical assistance for wastewater treatment plant operators on topics like water quality
monitoring, system optimization and current regulation. Assistance can be onsite at your
facility or at the WRWA office. Such training can help you perform AMO permit
requirements in-house rather than having to outsource tasks or hire additional staff. The
WRWA also provides a networking opportunity: you can contact other members of the
WRWA to learn how similar facilities have addressed phosphorus discharge limits.

Contacts: You can contact the WRWA at 715-344-7778 or email the association at
wrwa@wrwa.org. Visit the website at http://www.wrwa.org.
Appendix C: Funding Sources
This section contains a partial list of grants, loans and cost-share programs that you and your
partners might be able to use to fund adaptive management implementation. Each description also
includes some considerations for funding, including specific groups or practices that are eligible.
These descriptions don’t include the full considerations for each funding source, but include
considerations that may be relevant to an AMO plan. If you decide to pursue one or more of the
funding sources in this section, be sure to carefully review the criteria for eligibility.

Note: The funding sources listed here are included only as possible opportunities for funding or
examples of the types of funding available. You or the partners in your AMO plan may or may not be
eligible for the funding sources in this section.

Clean Water State Revolving Fund (Environmental Improvement Fund)

Source: State government through U.S. EPA

About: The CWSRF is a grant/loan program funded by the U.S. EPA and administered by the
states. The U.S. EPA provides grants to states, which loan out that money to fund
conservation projects. In Wisconsin, the DNR administers these loans through the
Environmental Improvement Fund (EIF).

Considerations:
 Point source facilities can directly apply for EIF loans. One of the main uses for EIF
loans is to support municipal efforts to meet WPDES permit requirements, so this
could be a good funding option for municipalities implementing an AMO plan.
 CAFOs are not eligible for CWSRF loans.34

More Information: For information about the EIF, including application instructions and
current interest rates, go to http://dnr.wi.gov/Aid/EIF.html.
For information about the CWSRF, go
to http://water.epa.gov/grants_funding/cwsrf/cwsrf_index.cfm.

Conservation Innovation Grants

Source: NRCS

About: In the CIG program, EQIP funds provide grants for innovative approaches to
conservation. According to a fact sheet about the program, CIG competitions place special
consideration on projects that benefit a large area, such as a watershed. Additionally, since
the AMO is a relatively new approach to water conservation, these grants could be a good fit
for funding. For a local example of the CIG program at work, the Board of Regents and

34"Funding Agricultural Best Management Practices with the Clean Water State Revolving Fund,” U.S. EPA,
2001,http://water.epa.gov/grants_funding/cwsrf/upload/2002_06_28_cwfinance_cwsrf_agfact.pdf.
 University of Wisconsin System received a 2012 CIG for a study of the use of the
Phosphorus Index in predicting the effect of management practices on snowmelt runoff.35

Considerations:
 Grants are awarded to non-federal entities including state and local governments,
tribes and individuals.
 Projects must include producers who are eligible for EQIP funding.
 Applicants for these grants must be able to provide their own technical assistance
for project implementation. (Unlike other programs, NRCS does not provide on-the-
ground assistance for these grants).
 Grants fund up to 50 percent of the total project cost. The remaining cost must be
covered by non-federal matching funds.36

More Information: A description of the program and links to fact sheets and past award
recipients is available at
http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/programs/financial/cig/?
&cid=nrcs143_008205.

Conservation Reserve Program/Conservation Reserve Enhancement Program

Source: Farm Service Agency (FSA)

About: The CRP is a Farm Bill cost-share program in which the federal government rents
agricultural land to take it out of production and implement conservation practices on that
land. The landowner receives rental payments based on the agricultural rental value of the
land and also receives reimbursements up to 50 percent of the cost of implementing BMPs
on that land.

The Conservation Reserve Enhancement Program (CREP) is a program within CRP that
focuses on environmentally sensitive land. Because this program focuses on more high-
priority farmland, it typically comes with a higher rental rate for land and additional
incentives.

Considerations: CRP and CREP come with several requirements for eligibility, including
the following:
 Barring unusual circumstances, the producer must have farmed the land in question
for at least a year
 The land and the practices implemented must meet a set of specific criteria, which
are available on program websites.

More Information: http://www.wi.nrcs.usda.gov/programs/crp.html

35"FY 2012 Conservation Innovation Grant Awardees," Natural Resources Conservation

Service, http://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/programs/financial/cig/?cid=stelprdb1048721.
36"Conservation Innovation Grant Program," Natural Resources Conservation Service,
2010, http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1044415.pdf .
Conservation Stewardship Program (CSP)

Source: NRCS

About: The CSP is a program that rewards agricultural producers for conservation
practices. This program is unique in that it pays for outcomes, rather than actions. Under
the CSP, farmers receive higher payments for higher conservation performance. This
structure provides additional incentive for farmers to take conservation practices seriously
and make their success a priority. NRCS agents assist farmers in the CSP with selection and
implementation of the practices. The NRCS evaluates conservation performance with a
point system and assesses farmland to ensure compliance with the program.

Considerations:
 Farmers can apply for the program if they control USDA-designated eligible
farmland for the terms of the contact and if the land already meets established
conservation standards.
 Farmers can receive payments up to $40,000 per year and $200,000 over the five-
year contract with the NRCS.
 Farmers can apply as individuals or as part of a group of farmers.37 The second
option may be helpful in AMO plans that include farmer collaboration.

More Information: The Wisconsin CSP site is

at http://www.wi.nrcs.usda.gov/programs/csp/cstp.html.

Environmental Quality Incentives Program (EQIP)

Source: NRCS

About: EQIP is a wide-ranging Farm Bill program that provides financial and technical
assistance to farmers implementing conservation practices. With help from the NRCS,
farmers who qualify for EQIP receive grants to implement practices such as grassed
waterways, vegetative buffers, barnyard manure management and others. Local NRCS
agents, with their technical expertise, can help farmers evaluate and select BMPs that will
be the most effective or feasible on their land. NRSC staff can also aid in BMP
implementation.

Considerations:
 For producers to receive EQIP reimbursements for technical assistance, the
assistance must be performed by a certified technical service provider (TSP)
through the NRCS.38 TSPs do not need to be NRCS staff, but can be independent
entities like consultants or staff at a nonprofit organization.

37 “Fact Sheet: Conservation Stewardship Program,” Natural Resources Conservation Service,

2011,http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1046181.pdf .
38 “Technical Service Providers,” Natural Resources Conservation

Service, http://www.wi.nrcs.usda.gov/programs/techpro.html.
  Applicants can receive up to $300,000 over a six-year period. In special
circumstances, an applicant can receive up to $450,000 in this period if the
proposed project has “special environmental significance.”39

More Information:
 For Wisconsin-specific EQIP information, go
to http://www.wi.nrcs.usda.gov/programs/eqip.html.
 For a list and contact information of certified TSPs in Wisconsin, go
to http://www.wi.nrcs.usda.gov/programs/techpro.html.
 For a list of all conservation practices eligible for EQIP in Wisconsin, go to
http://www.wi.nrcs.usda.gov/programs/eqip/eqip12/WI%20EQIP%20cookbook%
20FY12.pdf. This handbook also contains additional considerations for each
practice, such as the reimbursement per acre for a given practice and the maximum
reimbursement a farmer can receive for that practice. This information can help you
select BMPs to include in your AMO plan.
 The EQIP application is available as a PDF
at http://www.wi.nrcs.usda.gov/programs/eqip/eqip12/EQIP-CCC1200.pdf.

Great Lakes Restoration Initiative (GLRI)

Source: Great Lakes Restoration Initiative

About: The GLRI is a collaboration between several federal agencies, including the U.S. EPA,
the Council on Environmental Quality and the Department of Agriculture, that is invested in
water quality improvement projects in the Great Lakes region. One of its five main areas of
focus is reducing polluted runoff, and the initiative has awarded EPA grants to runoff
reduction projects in Wisconsin. For example, the Outagamie County Land Conservation
Department received a $747,741 EPA grant in 2011 to fund planting of vegetative buffer
strips to reduce runoff from agricultural land.40

Considerations: The GLRI awards grants for projects in five areas:

1. Cleaning up toxins and “areas of concern”
2. Controlling aquatic invasive species
3. Reducing polluted runoff to improve shore health
4. Restoring wetlands
5. Maintaining ongoing projects and partnerships and educating stakeholders

For 2012 and 2013, according to the GLRI, reducing nutrient inputs into Great Lakes waters
is one of the initiative’s top three priorities.41 However, some aspects of an AMO plan might
qualify for grants in other areas, such as runoff and sediment reduction through wetland
restoration.

39 "Environmental Quality Incentives Program," Natural Resources Conservation

Service, http://www.nrcs.usda.gov/wps/portal/nrcs/main/national/programs/financial/eqip.
40 “EPA 2011 Grants,” Great Lakes Restoration Initiative, last modified October 27,

2011, http://glri.us/2011epagrants.html.
41 "Great Lakes Restoration Initiative," GLRI, http://greatlakesrestoration.us .
 Various organizations are eligible for GLRI grants. Past recipients have included natural
resource departments, universities, land and conservation districts, nonprofit
organizations, parks departments and watershed associations.

More Information:
 General information about the program is available
at http://greatlakesrestoration.us.
 Information about obtaining GLRI grants through the U.S. EPA is available
at http://www.epa.gov/glnpo/glri.

Mississippi River Basin Initiative Grants

Source: NRCS

About: The MRBI is a program that encourages the adoption of voluntary conservation
practices among farmers in the Mississippi River Basin. The program uses existing
programs, such as WREP and CIG, to support and fund projects in this area. A grant from the
MRBI is funding a portion of the Yahara Lakes adaptive management pilot project in Dane
County.

Considerations: In Wisconsin, the selected watersheds for MRBI as of 2012 are the
Kickapoo, Upper Rock, Middle Rock, Rush-Vermillion and Grant-Little Maquoketa.42

More Information: The Wisconsin MRBI page, which includes payment rates and
descriptions of current initiative projects in Wisconsin, is at
http://www.wi.nrcs.usda.gov/programs/mrbi.html.

River Protection Planning and River Protection Management Grants

Source: Wisconsin DNR

About: These grants support activities to improve river health, include BMP
implementation, easement purchasing, policy development and outreach. They are intended
for recipients defined by state statute as “qualified river management organizations,” which
can be municipalities, tribal organizations or, with certain qualifications, nonprofit
organizations or lake associations.

Considerations: River protection planning grants typically fund the formation of

organizations or initiatives to protect rivers or surrounding land, while river protection
management grants generally fund more on-the-ground activities like the purchase of
conservation easements or the implementation of BMPs.43 Both types of grants could be

42 “Mississippi River Basin Healthy Watersheds Initiative (MRBI) Partner Briefing on Status and FY 2012
Funding Opportunities,” Natural Resources Conservation Service,
2011, http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1046715.pdf .
43 “River Protection Planning and River Protection Management Grants,” Wisconsin Department of Natural

Resources, last modified January 2, 2013,http://dnr.wi.gov/Aid/Rivers.html.

 used to fund different aspects of an AMO plan. Note that these grants include several
eligibility requirements, which are outlined in full in chapter NR 195, Wis. Adm. Code.

More Information: http://dnr.wi.gov/Aid/Rivers.html.

Sustainable Agriculture Research and Education (SARE) Grants

Source: The USDA’s Sustainable Agriculture Research and Education (SARE) program

About: The SARE program provides grants for innovation and education in sustainable
agriculture. The program provides a variety of grant categories, including farmer and
rancher grants and professional development grants for educators. SARE is divided into
four regions, and Wisconsin is part of the North Central region. The types of grants available
depend on the region, although there is a lot of overlap between the regions in grant
availability.

Past recipients of SARE grants in Wisconsin have included University of Wisconsin faculty,
nonprofit organizations and individual farmers.

Considerations: Depending on the type of practice, SARE grants can fund several aspects of
adaptive management. For example:
 A farmer transitioning from confined feeding to grazing may be eligible for a Farmer
Rancher grant.
 A partner from USDA or UW Extension who specializes in educating farmers about
conservation practices may be eligible for a Professional Development grant.

The amount of the award depends on the type of grant. Professional Development Program
grants range from $30,000 to $75,000 over 36 months, while Farmer Rancher grants range
from a maximum of $7,500 over 25 months for individual farmers to $22,500 for groups of
farmers over 25 months.44

More Information: The Wisconsin state SARE page, which includes grant application
materials and contact information for the state SARE coordinator, is at
http://www.northcentralsare.org/State-Programs/Wisconsin.

Targeted Runoff Management Grants

Source: Wisconsin DNR

About: These grants are intended for the design and constructions of nonpoint pollution-
reducing BMPs. The funding can go not only toward implementation, but also toward
staffing to design or complete the project. The size of the award depends on the tier into
which the project falls. The project tiers are listed below.
 Large-scale TMDL area
 Large-scale non-TMDL area
 Small-scale TMDL area

44"Our Grant Programs," Sustainable Agriculture Research & Education,

2012, http://www.northcentralsare.org/Grants/Our-Grant-Programs.
  Small-scale non-TMDL area

Considerations:
 Point sources, including CAFOs and industrial sources, are not eligible for this grant.
However, if you are a point source, you can encourage non-CAFO partner farmers to
apply for this grant.
 Projects in each tier except for small-scale TMDL area must be agricultural to be
eligible for the grant. In small-scale TMDL areas, this funding can also go toward
urban nonpoint reduction projects.
 Projects must have to do with improving water quality.

More Information: http://dnr.wi.gov/Aid/TargetedRunoff.html

Wildlife Habitat Incentives Program (WHIP)

Source: NRSC and U.S. Fish and Wildlife Service

About: WHIP is a voluntary cost-share program for private landowners to implement

practices to protect or restore wildlife habitat on their land. The NRCS provides technical
assistance and up to 75 percent cost share for habitat conservation practices.

Considerations:
 Land eligible for WHIP must be private agricultural or forest land or Indian land.
 The designated area maps for priority habitats are found at ftp://ftp-
fc.sc.egov.usda.gov/WI/whip/whippriorityareas_2.pdf.
 Habitat conservation practices that overlap with phosphorus reduction practices
include stream bank vegetation, wetland construction or restoration and planting
field buffers.

More Information: For information about WHIP in Wisconsin, go

to http://www.wi.nrcs.usda.gov/programs/whip.html. A full list of eligible practices for
WHIP as of 2011, as well as rates for cost-sharing, is available
at http://www.wi.nrcs.usda.gov/programs/WHIPcookbookFY11.pdf.

Wisconsin Trout Unlimited Access Fund

Source: Wisconsin Trout Unlimited (TU)

About: The TU access fund is a conservation easement purchasing program. TU partners

with other organizations interested in conservation to purchase land along coldwater
resources. The funding is directly available to local TU chapters, with whom you may build
partnerships to purchase conservation easements.

Considerations: According to TU’s description of the access fund, grant recipients are given
priority if they have partner organizations involved in the purchase or rental of land. This
criterion may lend itself well to a partner-based approach like an AMO plan.
 More Information:
http://www.wisconsintu.org/Programs/AccessFund/tabid/328/Default.aspx

Additional Funding Information

The list of potential funding sources above is a starting point for funding your AMO plan, and it does
not represent your only options for funding. You might find local, state or federal funding not listed
here that aligns with your watershed goals. There are online resources available to help you search
for additional funding opportunities. This section lists a few search tools for finding funding and
provides tips on applying for conservation funding.

Grants.gov (http://www.grants.gov) is a database of federal funding opportunities. Grants through

the U.S. EPA and FWS are available through this site. You can search by keyword, grantor agency,
funding category and other classifications.

The Catalog of Federal Funding Sources for Watershed Protection is a U.S. EPA tool for
searching for funding for watershed improvement projects. You can filter your search by the type of
project, eligible organizations and keywords. This tool is available at http://cfpub.epa.gov/fedfund.

The Great Lakes Information Network has a tool for searching grants for projects in the Great
Lakes region. This feature is available at http://www.great-
lakes.net/infocenter/news/funding.html#search.
Appendix D: Rural and Urban Practices for Reducing
Phosphorus
This section briefly describes rural and urban phosphorus control measures. The agricultural
control measures are summarized from a USDA publication on best management practices,
available at
http://www.ars.usda.gov/is/np/BestMgmtPractices/Best%20Management%20Practices.pdf.

Agricultural phosphorus reduction strategies can take place at several different points in the
phosphorus application process on a farm, from the immediate source (for example, livestock
feeding areas) to the edge of the field (for example, vegetative buffers). This section focuses on
controlling runoff through manure management and field methods. Although reducing phosphorus
at its source, as by decreasing the amount of phosphorus in livestock feed, can be an effective long-
term phosphorus control strategy, it’s not as effective in the short term as manure management
measures. For an AMO plan, the best course of action is to implement BMPs with significant short-
term effects.

Field Methods: Managing P Application to Reduce Runoff Risk

The following methods relate to spreading manure on fields and incorporating it into the soil.
Although manure is the focus in this section, many of these methods apply also to commercial
fertilizers. Both livestock producers who field-spread their animals’ manure and farmers who
primarily grow cash crops can implement these BMPs.

A straightforward, effective way to reduce the risk of significant phosphorus runoff is to time
manure application based on the weather. Phosphorus runoff is more likely when manure is
applied to frozen ground or melting snow or before a rainfall. Obviously, this method isn’t
foolproof, but simply following weather forecasts can help prevent runoff. Farmers can access
manure risk data before applying manure at http://www.manureadvisorysystem.wi.gov.

Method Summary Considerations

Barnyard runoff controls
Manure storage
Subsurface injection of
manure
Physical barriers and conduits on Relatively simple
farms, such as berms and gutters, means of reducing
divert clean water from washing into runoff through
waste-rich areas, such as fields or reducing water
feedlots contamination
Manure is stored in ponds, lagoons, or Gives farmers more
holding tanks until spreading or control over when
transport manure is spread, so
they can avoid
spreading at times
when surface runoff is
likely.
Manure is injected below the soil Does not work well in
surface during application, rather than rocky soils
spread on top of the soil, reducing the
waste that can run off with surface

Conservation tillage
Soil treatment
Cover crop cultivation
Strategic crop planting
(terraces, strip cropping)
water
Producers avoid turning over the soil Crop residues can trap
on some or all of their cropland, leaving phosphorus runoff
crop residues after harvesting on the and also reduce
land until the next planting season. erosion, which is a
good talking point
with producers.
The soil on which manure is spread is Soil treatment
treated with chemicals, such as gypsum requires additional
(a byproduct of coal combustion) that steps on the part of
reduce soluble P runoff the farmer (obtaining
soil treatment
materials and
spreading them on
soil).
Farmers plant a crop (often a legume, Besides reducing P
such as alfalfa) on fields not in runoff, this method
production, reducing the amount of can provide additional
water than runs off the field and benefits for the farm,
therefore reducing P loss. Crops can such as erosion
also take up residual soil P if they’re control and additional
harvested. nutrients for cash
crops that are later
grown on fields used
for cover crops.
Cropland is modified in a way that Initial construction
reduces erosion and surface runoff. For may be relatively
example, constructing terraces reduces expensive
runoff down a sloped field

Barrier Methods: Preventing P from Reaching Waters

The BMPs below are designed to act as barriers or sponges to nutrients and sediment to prevent
them from reaching waterways. These practices are options for livestock producers, cash crop
producers and non-agricultural landowners.
Method Summary Considerations
Grassed Channels lined with grass are Have the additional benefit of reducing
waterways constructed in and near erosion on the farm
agricultural fields, trapping
sediment in surface runoff events
Vegetative Vegetation is planted between If considering vegetative buffers, you should
buffers fields and waterways, trapping take into account the value of the crop
sediment, reducing P runoff into acreage being converted to a buffer. Buffers
the waterway, and taking up P also vary in effectiveness based on the
from the soil topography and type of runoff, so these
areas require monitoring to determine their
effect.
Grazing On farms where animals are
management allowed to graze, the animals are
kept away from streams and
stream banks and not permitted
to graze on land with a high
chance of surface runoff, such as a
steep hillside
Reduces direct application of manure to
waterways. More likely to be applicable on
smaller operations rather than CAFOs. Can
be as simple as putting up a fence between
pasture and waterways.

Nutrient Management Plans

NMPs don’t fit the description of one specific BMP, but encompass a wide range of runoff and
nutrient control practices on a farm. These plans can apply to both crop and livestock operations).
To develop an NMP, farmers work individually with conservation staff (for example, a
representative from a local conservation department or NRCS office) to assess sources of nutrient
loss on their farm and to develop a plan to prevent those losses. The plan itself may be developed
by crop consultants or by trained farmers and is reviewed by the local conservation department.
NMP development will rely heavily on the P Index of the farmer’s fields. According to the Wisconsin
Department of Agriculture, Trade and Consumer Protection (DATCP), farmers are required to have
an NMP to apply nutrients if mandated by their municipality or for eligibility for cost-sharing.

For more information about nutrient management plans, go

to http://datcp.wi.gov/farms/nutrient_management/index.aspx.

Urban Runoff Management Practices

Depending on the type of land use in your action area, your plan may include urban BMPs as well as
agricultural practices. There are many potential sources of nutrient runoff in cities and towns – to
name a few, fertilizer applied to yards, pet waste, yard clippings and sediment from construction
sites. Stormwater collects phosphorus from these substances and drains into surrounding bodies of
water. The surface characteristics of urban areas, with neatly mown lawns and impervious paved
areas, contribute to the flow of phosphorus-rich stormwater.

Phosphorus control strategies in urban areas follow many of the same general principles as rural
phosphorus control strategies – reduce phosphorus at the source or prevent it from reaching
waterways. For example, the following practices are common urban runoff reduction practices:
Method Summary
Stormwater retention ponds Artificial basins are constructed to collect store
runoff from the surrounding area.
Rain barrels/gardens Residents or businesses strategically place
barrels or plant gardens to collect rainwater
from roofs or gutters, reducing the amount of
rainwater that runs off lawns.
Pervious pavement Special types of pavement that are more
permeable to water than traditional pavement
are used for streets, driveways and lots. More
water seeps through the pavement into the
ground, reducing the amount of water running

Yard waste collection/composting
Silt fences
off the surface.
Residents avoid getting yard waste such as
leaves or grass clippings into the street, where
they could wash away. Instead, residents either
compost yard waste or collect yard waste for
pickup by municipal services.
Special fences are built around construction
sites to trap sediment runoff.